GR 252351; (July, 2021) (Digest)
G.R. No. 252351 , July 07, 2021
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.
FACTS
The accused-appellant XXX was charged with Qualified Rape under Articles 266-A and 266-B of the Revised Penal Code (Criminal Case No. 04-2755) and with violation of Section 10(A), Article VI of Republic Act No. 7610 (Criminal Case No. 04-2754). The victim, AAA, was 15 years old and the stepdaughter of the accused. The prosecution’s version established that on March 11, 2004, around 7:00 PM, appellant, after arriving home from a drinking spree, asked AAA to give him a massage. He then switched off the lights, kissed and caressed her breasts, and punched her twice when she resisted. He followed her to the bedroom, threatened to kill her, her mother, and siblings if she made a sound, and then had carnal knowledge of her. AAA reported the incident to her aunt days later. A medico-legal examination revealed hymenal lacerations. On March 27, 2004, when AAA, accompanied by barangay officials, went to get her belongings, appellant slapped her on the face, an act witnessed by the officials. The defense denied the accusations, claiming AAA ran away after being scolded and that the injuries might have been caused by another person. The Regional Trial Court found appellant guilty of both charges. The Court of Appeals affirmed the RTC decision. Appellant appealed to the Supreme Court.
ISSUE
1. Whether the Court of Appeals erred in affirming appellant’s conviction for Qualified Rape.
2. Whether the Court of Appeals erred in affirming appellant’s conviction for violation of Section 10(A), Article VI of R.A. No. 7610 .
RULING
The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATIONS to the awards of damages.
1. On the conviction for Qualified Rape: The Court found the appeal without merit. It held that AAA’s testimony was credible, consistent, and candid. Minor inconsistencies regarding the location of the rape did not impair her credibility. The medico-legal findings corroborated her account. The Court ruled that the elements of rape were present: carnal knowledge was accomplished through force and intimidation, and the qualifying circumstances of minority and relationship were duly proven (AAA was 15 and appellant was her stepfather). The defense of denial and alibi could not prevail over AAA’s positive identification.
2. On the conviction for violation of R.A. No. 7610 : The Court affirmed the conviction. Appellant admitted to slapping AAA. The act constituted child abuse as defined under Section 10(a) of R.A. No. 7610 , as it was a deliberate act of laying hands on a child, debasing her intrinsic worth, and was prejudicial to her development. His claim that it was a disciplinary act was rejected.
The Court modified the damages awarded. For Qualified Rape: Civil Indemnity, Moral Damages, and Exemplary Damages were increased to P100,000.00 each. For violation of R.A. No. 7610 : Civil Indemnity was increased to P50,000.00, Moral Damages to P50,000.00, and Exemplary Damages to P50,000.00. Interest at 6% per annum on all damages awarded was imposed from the finality of judgment until full payment.