GR 263553; (November, 2023) (Digest)
G.R. No. 263553 , November 20, 2023
People of the Philippines, Plaintiff-Appellee, vs. XXX263553, Accused-Appellant.
FACTS
The accused-appellant, the paternal grandfather of AAA, was charged with five counts of rape under Article 266-A(1)(a) of the Revised Penal Code, as amended. The Informations alleged that from January to May 2015, he had carnal knowledge of his 14-year-old granddaughter through force, threat, or intimidation. During trial, AAA testified in detail about the repeated sexual assaults. She stated that the accused-appellant began molesting her before she was ten, with full penile penetration starting when she was thirteen. The rapes in 2015 occurred when she was left alone at home. He used threats of violence, including punching her stomach and threatening to kill her, to secure her compliance and silence. Her younger brother, BBB, corroborated her account, testifying that he witnessed one incident through a gap in the wall where he saw the accused-appellant on top of and kissing AAA. The defense consisted of denial and alibi, claiming AAA was motivated by anger after being scolded.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for five counts of qualified rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim’s testimony, when categorical, consistent, and straightforward, deserves great weight. AAA’s detailed narration of the events, including the specific circumstances of each rape and the threats employed, was found credible and sufficient to establish guilt beyond reasonable doubt. The Court rejected the defense of denial, which is inherently weak against positive identification. It also noted that the victim’s initial silence and delay in reporting, attributed to the accused-appellant’s threats, did not impair her credibility, as such reaction is common for victims, especially minors abused by a relative in a position of authority.
The crime was properly qualified under Article 266-B due to the victim’s minority (under 18) and her relationship to the offender as a grandfather, a relative within the third civil degree of consanguinity. While these circumstances would have warranted the death penalty, Republic Act No. 9346 prohibited its imposition. Consequently, the penalty for each count was reduced to reclusion perpetua without eligibility for parole. The Court also modified the awards of damages, increasing civil indemnity, moral damages, and exemplary damages to P100,000.00 each for every count of rape, in line with prevailing jurisprudence. All monetary awards were subject to legal interest.