G.R. No. 241787 , March 15, 2021
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.

FACTS

Two Informations were filed against accused-appellant XXX for two counts of qualified rape allegedly committed against his daughter, AAA, who was nine years old in May 2007. The prosecution evidence, primarily from AAA’s testimony, established that in May 2007, while her mother was abroad, XXX told her to lie down, removed her clothing, threatened to kill her if she resisted, and forcibly inserted his penis into her vagina, causing her pain. He raped her again the following day and repeated the threat to kill her if she reported it. In March 2011, he attempted to rape her again, but she resisted and reported the incidents to her uncle, leading to a police report and a medical examination. The defense presented XXX’s denial, claiming AAA was in the custody of her grandmother at the time and that the case was instigated by the grandmother due to personal animosity. The Regional Trial Court found XXX guilty of two counts of qualified rape and sentenced him to reclusion perpetua for each count, with damages. The Court of Appeals affirmed the conviction with modifications, increasing the amounts of civil indemnity, moral damages, and exemplary damages.

ISSUE

1. Whether the trial court gravely erred in relying on the private complainant’s testimony.
2. Whether the trial court gravely erred in admitting the medico-legal report despite the non-presentation of the examining physician.
3. Whether the trial court gravely erred in disregarding the accused-appellant’s defense of denial.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court held that the victim’s testimony was credible, categorical, straightforward, and consistent with human nature, making it sufficient to convict. The findings of the lower courts on credibility were upheld. On the second issue, the Court ruled that the medico-legal report is merely corroborative and not indispensable for conviction in rape cases, especially when the victim’s testimony is clear and credible. The non-presentation of the examining physician does not undermine the prosecution’s case. On the third issue, the Court held that denial is an inherently weak defense and cannot prevail over the positive and credible testimony of the victim. The accused-appellant’s claim that the victim was with her grandmother was unsubstantiated and uncorroborated. All elements of qualified rape were proven: sexual intercourse occurred through force or intimidation, and the aggravating circumstances of minority and relationship were established. The Court imposed the penalty of reclusion perpetua for each count without eligibility for parole and increased the awards for civil indemnity, moral damages, and exemplary damages to P100,000.00 each, subject to 6% interest per annum from finality until fully paid.