G.R. No. 266706, June 26, 2024
People of the Philippines, Plaintiff-Appellee, vs. ZZZ, Accused-Appellant.

FACTS

Accused-appellant ZZZ was charged with multiple crimes before the Regional Trial Court (RTC) of Dagupan City involving his family: three counts of Rape under Article 266-A(1)(a) of the Revised Penal Code (RPC); one count of Rape by Sexual Assault under Article 266-A(2) of the RPC; one count of Acts of Lasciviousness under Republic Act (R.A.) No. 7610; three counts of Child Abuse under R.A. No. 7610; and one count of Violation of Section 5(a) of R.A. No. 9262. The charges stemmed from acts allegedly committed against his daughters, AAA, BBB, CCC, and DDD, and his wife, EEE.
The Informations detailed the following allegations:
* Criminal Case No. 2017-1045-D (Rape by Sexual Assault): In April 2009, ZZZ inserted his finger into the genital orifice of his 10-year-old daughter, AAA.
* Criminal Case No. 2017-1046-D (Rape): In April 2011, ZZZ had carnal knowledge of his 12-year-old daughter, AAA.
* Criminal Case No. 2017-1047-D (Rape): In October 2012, ZZZ had carnal knowledge of his 13-year-old daughter, AAA.
* Criminal Case No. 2017-1048-D (Rape): In November 2012, ZZZ had carnal knowledge of his 13-year-old daughter, AAA.
* Criminal Case No. 2017-1049-D (Acts of Lasciviousness): In August 2015, ZZZ touched the breast of his 16-year-old daughter, AAA.
* Criminal Case Nos. 2017-1050-D to 1052-D (Child Abuse): On September 19, 2017, ZZZ committed acts of physical violence against his daughters BBB (16 years old), CCC (15 years old), and DDD (17 years old), including spanking, punching, choking, and dragging.
* Criminal Case No. 2017-1053-D (Violation of R.A. 9262): On September 19, 2017, ZZZ punched his wife, EEE, on the chest.
The RTC convicted ZZZ of two counts of Rape under Article 266-A(1)(a), one count of Rape by Sexual Assault under Article 266-A(2), and four counts of Slight Physical Injuries under Article 266 of the RPC. The Court of Appeals (CA) affirmed the RTC’s decision with modifications. ZZZ appealed the CA decision.

ISSUE

The core issue for the Supreme Court’s resolution was the correctness of the CA’s affirmance of ZZZ’s convictions, which necessarily involved a review of the factual findings and legal conclusions regarding the crimes charged, particularly the sufficiency of the prosecution’s evidence to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with modifications. The Court found the testimonies of the victims, particularly AAA, to be credible, straightforward, and consistent. The Court emphasized that in cases of rape, the credibility of the victim is paramount, and the testimony of a lone witness, if credible and positive, is sufficient to sustain a conviction. The Court also noted that the relationship of father and daughter between the accused and the victim substantiates the moral ascendancy and force or intimidation employed in the commission of the rape.
The Court modified the penalties and damages awarded in accordance with prevailing jurisprudence. For the crimes of Rape under Article 266-A(1)(a), the Court imposed reclusion perpetua without eligibility for parole for each count. For the crime of Rape by Sexual Assault under Article 266-A(2), the Court also imposed reclusion perpetua. The Court awarded civil indemnity, moral damages, and exemplary damages to AAA for the rape and sexual assault convictions. The convictions for Slight Physical Injuries under Article 266 of the RPC were also affirmed with corresponding penalties and damages.