GR 242278; (December, 2020) (Digest)
G.R. No. 242278, December 09, 2020
People of the Philippines, Plaintiff-Appellee, vs. Christian Manuel y Villa, Accused-Appellant.
FACTS
The accused-appellant, Christian Manuel y Villa, was convicted by the Regional Trial Court for Acts of Lasciviousness, Attempted Qualified Rape, Qualified Rape, and Qualified Rape by Sexual Assault against his stepdaughter, AAA. The incidents occurred between June 2009 and August 2010 in Manila. The prosecution presented AAA’s detailed testimony, describing specific acts where the accused-appellant forced her to hold his penis, attempted and succeeded in having carnal knowledge, and forced her to perform oral sex. AAA was nine to eleven years old during the assaults. Her mother, BBB, corroborated the report and testified to AAA’s resulting trauma. The defense consisted solely of the accused-appellant’s denial, claiming the acts were impossible in their small dwelling where the family slept together.
ISSUE
The core issue is whether the accused-appellant’s guilt for the complex crimes charged was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction with modification. The Court found AAA’s testimony credible, straightforward, and consistent, fulfilling the stringent standard for proving rape cases which relies heavily on the victim’s candid account. The defense of denial, unsubstantiated by clear and convincing evidence, cannot prevail over positive identification. The Court applied the principle of pro reo where the allegations in the Information and the evidence proved diverge. For Criminal Case No. 11-288378, charged as Qualified Rape by Sexual Assault under Article 266-A(2) of the Revised Penal Code, the act proved was forcing the victim’s mouth to touch the penis. This constituted the lesser crime of Acts of Lasciviousness under Section 5(b) of Republic Act No. 7610, as it involved lascivious conduct falling short of oral sex penetration. The accused was properly convicted of this lesser included offense. All other convictions were upheld. The qualifying circumstance of relationship as a stepfather was duly proven, warranting the imposition of the maximum penalties.