G.R. No. 263227 , August 02, 2023
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant

FACTS

Three Informations were filed charging accused-appellant XXX with three counts of Incestuous Rape under Article 266-B of the Revised Penal Code, as amended. The charges involved his biological daughters: two counts against AAA (14 years old) on March 7 and 9, 2015, and one count against BBB (11 years old) on March 13, 2015. The prosecution presented the testimonies of AAA, BBB, their older sister CCC, and the medical findings of Dr. Florilyn Pimentel, who found hymenal lacerations on both victims. AAA testified that her father raped her on two occasions, using threats of death. BBB testified that her father raped her while she was cooking, also threatening to kill the family if she told anyone. CCC learned of the incidents from AAA on March 14, 2015, and reported them to authorities, leading to medical examinations on March 16, 2015. The defense presented XXX, who denied the accusations, claiming they were fabricated due to a conflict with CCC over land and because he had scolded his daughters for skipping school. The Regional Trial Court found XXX guilty beyond reasonable doubt on all counts and sentenced him to reclusion perpetua without parole for each count, plus damages. The Court of Appeals affirmed the RTC’s decision in toto.

ISSUE

Whether the prosecution proved XXX’s guilt beyond reasonable doubt for three counts of Incestuous Rape.

RULING

Yes. The Supreme Court affirmed the conviction. The prosecution sufficiently established all elements of Qualified Rape: (1) sexual congress; (2) with a woman; (3) by force and without consent; (4) the victims were under 18 years of age; and (5) the offender is a parent of the victims. The Court upheld the credibility of the victims’ straightforward testimonies, which were consistent on material points and corroborated by medical evidence. Minor inconsistencies in their narratives were deemed inconsequential and even expected given their tender age and the traumatic nature of the crime. The Court rejected the defense’s arguments regarding the victims’ alleged unnatural behavior, noting that different people react differently to trauma and that the father’s moral ascendancy and threats instilled fear, explaining their submission. The defense of denial and imputation of ill motive were insufficient to overcome the positive identification and credible testimonies of the victims. The penalties and awards of damages imposed by the lower courts were affirmed.