G.R. No. 232500, July 28, 2020
People of the Philippines, Plaintiff-Appellee, vs. ZZZ, Accused-Appellant

FACTS

The accused-appellant, ZZZ, was charged in six separate Informations before the Regional Trial Court (RTC) of Calapan, Oriental Mindoro. The charges included: 1) violation of Section 5(i) in relation to Section 6(f) of R.A. No. 9262 (Anti-Violence Against Women and Their Children Act) for inflicting psychological violence on his 12-year-old son, AAA (Criminal Case No. CR-08-9135); 2) violation of Section 5(a) in relation to Section 6(a) of R.A. No. 9262 for physically assaulting AAA, causing hematoma (Criminal Case No. CR-08-9136); 3) Rape of his 16-year-old daughter, BBB, in May 2003 (Criminal Case No. CR-08-9180); and 4) three counts of Acts of Lasciviousness against his 14-year-old daughter, CCC, on March 18, 19, and 20, 2008 (Criminal Cases Nos. CR-08-9183, CR-08-9184, and CR-08-9185), in relation to R.A. No. 7610. The prosecution presented evidence that on April 19, 2008, the accused-appellant, heavily drunk, boxed his son AAA, causing his mouth to bleed. In May 2003, he brought his daughter BBB to get firewood, ordered her to lie down, and forcibly had carnal knowledge of her. In March 2008, on three consecutive nights, he entered the room where his daughter CCC was sleeping, touched her vagina, mashed her breasts, and embraced her against her will. The accused-appellant denied all accusations, claiming his children were influenced by his other daughter, EEE. The RTC found him guilty on all charges. The Court of Appeals affirmed the RTC’s decision. The case was elevated to the Supreme Court on appeal.

ISSUE

The core issue for the Supreme Court’s resolution was whether the Court of Appeals correctly affirmed the trial court’s judgment finding the accused-appellant guilty beyond reasonable doubt of the crimes charged.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the November 28, 2016 Decision of the Court of Appeals with MODIFICATIONS. The Court held that the prosecution successfully proved the guilt of the accused-appellant beyond reasonable doubt. The testimonies of the private complainants (AAA, BBB, and CCC) were found to be credible, straightforward, and consistent. The Court emphasized that testimonies of child-victims are given full weight and credit, and the relationship of the accused as their father lends credibility to their allegations. For the rape charge (Criminal Case No. CR-08-9180), the Court affirmed the penalty of reclusion perpetua without eligibility for parole and increased the awarded damages in line with prevailing jurisprudence. For the three counts of Acts of Lasciviousness (Criminal Cases Nos. CR-08-9183 to 9185), the Court modified the penalty. It held that the crimes were committed through sexual assault under Section 5(b) of R.A. No. 7610, not through lascivious conduct under Article 336 of the Revised Penal Code. Applying the Indeterminate Sentence Law, the Court imposed the penalty of reclusion temporal in its medium period as maximum. The Court also imposed the proper fines and damages for the violations of R.A. No. 9262. The dispositive portion of the Supreme Court’s Decision modified the penalties and awards accordingly.