GR 248245; (August, 2020) (Digest)
G.R. No. 248245, August 26, 2020
People of the Philippines, Plaintiff-Appellee v. HHH, Accused-Appellant
FACTS
Accused-appellant HHH was charged with six counts of rape against his three minor daughters: AAA, BBB, and CCC. The charges consisted of three counts of Rape by Sexual Assault and three counts of Statutory Rape. The incidents occurred in Angeles City between 2012 and 2014. AAA testified to three separate assaults on May 13, 2014: at 7:00 a.m. (forced to grasp his penis, anal penetration, and licking of her vagina), at 12:00 p.m. (forced to masturbate him followed by vaginal penetration), and at 7:00 p.m. (insertion of his finger into her vagina). BBB testified to two incidents in 2012 when she was 10 years old, involving kissing, touching, and vaginal penetration. CCC testified to an incident in March 2014 when she was 11 years old, where she was forced to masturbate him while he inserted his finger into her vagina. The sisters reported the abuses after learning they had all been victimized. HHH denied the charges, claiming he was working as a jeepney driver during one of the alleged incidents. The Regional Trial Court found HHH guilty on all counts. The Court of Appeals affirmed the RTC decision. HHH appealed to the Supreme Court.
ISSUE
The core issue is whether the Court of Appeals correctly affirmed the conviction of accused-appellant HHH for three counts of Rape by Sexual Assault and three counts of Statutory Rape.
RULING
The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATIONS to the awards of damages. The Court held that all elements of the crimes were proven beyond reasonable doubt. The testimonies of the minor victims were credible, consistent, and corroborated. The defense of denial and alibi was weak and could not prevail over the positive identification and categorical declarations of the victims. The Court modified the awards of civil indemnity, moral damages, and exemplary damages for the crimes of Statutory Rape to P100,000.00 each, and for the crimes of Rape by Sexual Assault to P50,000.00 each, in accordance with prevailing jurisprudence. The Court also imposed interest at the rate of six percent (6%) per annum on all damages awarded from the date of finality of the judgment until fully paid.