G.R. No. 265272 , November 06, 2023
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ZZZ, ACCUSED-APPELLANT.

FACTS

The accused-appellant, ZZZ, was charged with Qualified Rape under the Revised Penal Code and violation of Republic Act No. 7610 (RA 7610) for sexually abusing his 14-year-old biological daughter, AAA. The prosecution alleged two incidents in November and December 2016, wherein ZZZ entered AAA’s room, fondled her, and had carnal knowledge with her. AAA testified that she was threatened by ZZZ with a scythe and with death if she reported the acts. Her testimony was corroborated by her younger sibling, BBB, who stated that ZZZ began sleeping beside AAA when their mother, YYY, worked in another town. AAA eventually confessed to her mother, leading to a police report and a medical examination that revealed healed lacerations consistent with sexual intercourse.
ZZZ denied the allegations, presenting an alibi. He claimed that on the dates in question, other family members were present in the same room and that nothing unusual occurred. He asserted that AAA was an obedient daughter and he did not know her motive for accusing him. During pre-trial, the parties stipulated on ZZZ’s paternity, AAA’s age at the time of the incidents, and their cohabitation. The Regional Trial Court convicted ZZZ of both charges, a decision affirmed by the Court of Appeals.

ISSUE

The core issue is whether the prosecution proved ZZZ’s guilt for Qualified Rape and violation of RA 7610 beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s categorical, consistent, and unwavering narration of the harrowing incidents, including specific details like the use of a scythe as a threat, was found credible and sufficient to establish the elements of rape. The Court noted that her failure to shout for help was justified by the fear instilled by her father’s threats, which is understandable given his moral ascendancy and parental authority over her. The medical findings of healed lacerations, while not conclusive, lent credence to her account.
The defense of denial and alibi was deemed inherently weak and could not prevail over AAA’s positive identification. The Court also ruled that the charge under RA 7610 was subsumed by the conviction for Qualified Rape. Since the rape was committed against a child, the provisions of RA 7610 are deemed absorbed by the Revised Penal Code, as the latter prescribes a graver penalty. Thus, ZZZ was correctly held liable only for Qualified Rape. The penalties and awards of damages imposed by the lower courts were sustained, with the modification that the civil indemnity, moral damages, and exemplary damages shall earn legal interest.