G.R. No. 235662 July 24, 2019
The People of the Philippines, Plaintiff-Appellee vs. XXX, Accused-Appellant

FACTS

The accused-appellant XXX was charged with two counts of qualified rape against his daughters, AAA and BBB, and one count of lascivious conduct against BBB. The prosecution established that AAA was raped on March 14, 2009, and on multiple other occasions. BBB testified that in 2009, her father attempted to rape her and was interrupted by the arrival of her brother. She also detailed repeated instances where appellant would molest her and AAA while they slept. The victims, both minors at the time, delayed reporting due to fear and initial disbelief from their mother. The defense consisted of a denial and an alibi, claiming the accusations were fabricated because his family was angry about his relationship with another woman.
The Regional Trial Court convicted XXX on all counts. The Court of Appeals affirmed the convictions but modified the penalties and damages. The accused then appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the witnesses.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of qualified rape and one count of lascivious conduct.

RULING

The Supreme Court dismissed the appeal and affirmed the modified decision of the Court of Appeals. On the issue of credibility, the Court upheld the findings of the lower courts, emphasizing that the testimonies of the victims were candid, consistent, and credible. The Court ruled that the victims’ delay in reporting the crimes, given their youth, fear of their father, and familial pressure, did not undermine their credibility. The defense of denial and alibi could not prevail over the positive and categorical identification by the victims.
Regarding the legal qualification of the crimes, the Court affirmed that the rapes were qualified by the minority of the victims and their relationship to the offender as their father, warranting the penalty of reclusion perpetua without parole for each count. For the lascivious conduct under Section 5(b) of Republic Act No. 7610, the Court sustained the penalty of reclusion perpetua, as the act was committed under the qualifying circumstance of the offender being the victim’s parent. The Court also modified the awarded damages in line with prevailing jurisprudence, increasing the civil indemnity, moral damages, and exemplary damages for qualified rape to ₱100,000.00 each. All monetary awards were subject to legal interest.