G.R. No. 255387 , March 29, 2023
People of the Philippines, Plaintiff-Appellee, vs. XYZ, Accused-Appellant.

FACTS

The accused-appellant, XYZ, was charged with two counts of Rape under Article 266-A of the Revised Penal Code, as amended. The Informations alleged that in May 2016 and on August 27, 2017, in Zambales, the accused-appellant, the live-in partner of the victim’s aunt with whom the victim AAA was living, through force, threat, and intimidation, had carnal knowledge of AAA against her will. AAA was 16 years old in May 2016 and 17 years old in August 2017. The prosecution’s version established that AAA had been under the custody of her aunt BBB and the accused-appellant since she was 10. The first incident occurred in May 2016 when the accused-appellant dragged AAA into a room, undressed her, and had carnal knowledge of her. Subsequent incidents occurred under an Arosep tree. The last incident was on August 27, 2017, where the accused-appellant again raped AAA and threatened to kill her or send her away if she told anyone. AAA revealed the abuse to her aunt BBB the following day. The defense denied the accusations, claiming the charges were fabricated so BBB could get rid of him and sell his farm animals. The Regional Trial Court (RTC) found the accused-appellant guilty of two counts of Rape and sentenced him to reclusion perpetua for each count, with corresponding damages. The Court of Appeals (CA) affirmed the RTC’s decision but modified the penalty to qualified rape, imposing reclusion perpetua without eligibility for parole for each count and increasing the awards for civil indemnity, moral damages, and exemplary damages to Php 100,000 each per count.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of Rape.

RULING

The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals. The Court held that all elements of rape were established: the accused-appellant had carnal knowledge of AAA, and it was accomplished through force and intimidation, as evidenced by AAA’s credible testimony detailing the acts and the threats made. The Court found AAA’s testimony to be credible, consistent, and corroborated by the medico-legal report showing hymenal lacerations. The Court rejected the accused-appellant’s defenses of denial and alleged ill motive, noting that such denial cannot prevail over the positive and categorical testimony of the victim. The Court also found no merit in the claim of delayed reporting, as the delay was explained by AAA’s age and the threats made against her. The relationship between the accused-appellant (the common-law spouse of AAA’s aunt and a person exercising moral ascendancy over her) and AAA’s minority qualified the crime to qualified rape under Article 266-B of the Revised Penal Code. The proper penalty is reclusion perpetua without eligibility for parole for each count, in accordance with Republic Act No. 9346 . The awards of Php 100,000 as civil indemnity, Php 100,000 as moral damages, and Php 100,000 as exemplary damages for each count of rape, with interest at 6% per annum from finality until full payment, were sustained.