GR 276383; (August, 2025) (Digest)
G.R. No. 276383, August 06, 2025
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, vs. XXX276383, ACCUSED-APPELLANT.
FACTS
Nine separate Informations were filed against accused-appellant XXX276383, the maternal uncle of the victims, for various sexual offenses against his three nieces and one nephew: AAA276383, BBB276383, and CCC276383. The charges included one count of rape, one count of sexual assault, two counts of lascivious conduct under Republic Act No. 7610, and four counts of acts of lasciviousness under the Revised Penal Code in relation to R.A. No. 7610. The incidents occurred from 2010 to 2013. The accused pleaded not guilty. The prosecution presented the victims as witnesses. AAA276383 testified that in 2010, when she was 11, the accused punched her, gagged her, forced her to undress, and raped her in a room while her grandmother and cousin were sleeping nearby. She also testified to other incidents of sexual assault and lascivious conduct. The defense claimed the charges were fabricated due to a family grudge. The Regional Trial Court convicted the accused, and the Court of Appeals affirmed the conviction with modifications.
ISSUE
The main issue is whether the Court of Appeals correctly affirmed the conviction of accused-appellant XXX276383 for the crimes charged.
RULING
The Supreme Court affirmed the decision of the Court of Appeals with modifications. The Court held that the presence of other people does not negate the commission of rape, as it can occur even in public circumstances. The testimonies of the victims, particularly AAA276383, were found credible, straightforward, and consistent. The defense of denial and alibi could not prevail over the positive identification and credible narration of the victims. The qualifying circumstances of minority and relationship were duly proven. The Court modified the penalties and awarded damages in accordance with prevailing jurisprudence. The accused was found guilty of one count of rape under Article 266-A(1) of the Revised Penal Code, one count of sexual assault under Article 266-A(2), two counts of lascivious conduct under Section 5(b) of R.A. No. 7610, and four counts of acts of lasciviousness under Article 336 of the Revised Penal Code in relation to Section 5(b) of R.A. No. 7610.