GR 248777; (July, 2020) (Digest)
G.R. No. 248777 , July 07, 2020
People of the Philippines, Plaintiff-Appellee, vs. AAA, Accused-Appellant.
FACTS
The accused-appellant, AAA, was charged with Qualified Rape for having carnal knowledge of his 15-year-old daughter, BBB, in December 2015. The prosecution presented BBB, who testified that after attending a misa de gallo, her father offered her coffee at a wake. Upon returning home and changing clothes, AAA arrived, told her to lie down, undressed her and himself, laid on top of her, kissed her, and inserted his penis into her vagina, causing her pain. BBB reported the incident to the DSWD with her aunt, leading to AAA’s warrantless arrest. AAA denied the accusation, claiming BBB fabricated the story at her aunt’s instance and that he was driving his multicab during the day and sleeping at a waiting shed at night during the alleged incident. His son corroborated that BBB stayed behind with friends after the mass. The Regional Trial Court found AAA guilty of Qualified Rape and sentenced him to Reclusion Perpetua without eligibility for parole, plus damages. The Court of Appeals affirmed the RTC decision.
ISSUE
1. Whether the warrantless arrest of AAA was valid.
2. Whether the prosecution proved AAA’s guilt for the crime of Qualified Rape beyond reasonable doubt.
RULING
1. On the warrantless arrest: The Court ruled that AAA is estopped from assailing any irregularity in his arrest because he failed to raise the issue or move to quash the information before his arraignment. Any objection to the arrest is deemed waived. Furthermore, even if the arrest were invalid, it would not invalidate a judgment rendered after a trial free from error.
2. On the guilt for Qualified Rape: The Court affirmed the conviction. The testimony of the victim, BBB, was found to be credible, straightforward, and consistent. In rape cases, the victim’s testimony is given greater weight, especially when the accused is a close relative. The Court rejected AAA’s arguments that BBB’s testimony was too simplistic and that the delay in reporting was contrary to human experience, noting that delay does not undermine credibility, especially given the victim’s age and the accused’s moral ascendancy as her father. The qualifying circumstance that the victim was under 18 and the offender was her parent was duly proven. The penalty of Reclusion Perpetua without eligibility for parole was correctly imposed, as the crime warranted the death penalty were it not for Republic Act No. 9346 . The award of damages was sustained.