### Facts:
1. **Incident Description**:
– **June 2, 2005**: Appellant Emiliano De Chavez sexually assaulted his 13-year-old daughter “XXX” by inserting his finger into her genitalia while she was asleep.
– **June 3, 2005**: De Chavez raped “XXX” by having carnal knowledge with her. “YYY,” the sister, witnessed this incident.
– **June 4, 2005**: De Chavez again sexually assaulted “XXX” by inserting his finger into her genitalia.
– **September 30, 2005**: De Chavez raped “XXX” again by inserting his penis into her vagina.
2. **Reporting**:
– The continued abuse prompted “XXX” to report the incidents to the police on September 30, 2005.
3. **Charges**:
– **Criminal Case No. 13940-06-C**: Sexual assault on June 2, 2005.
– **Criminal Case No. 13941-06-C**: Rape on June 3, 2005.
– **Criminal Case No. 13942-06-C**: Rape on September 30, 2005.
– **Criminal Case No. 13943-06-C**: Sexual assault on June 4, 2005.
4. **Procedural Posture**:
– **RTC Calamba City, Branch 92**: On February 27, 2013, found De Chavez guilty and sentenced him for the crimes with penalties including imprisonment and monetary damages.
– **Court of Appeals (CA)**: On June 20, 2014, affirmed the RTC’s decision with minor modifications in the exemplary damages.
– **Supreme Court**: On appeal from the CA’s decision.
### Issues:
1. **Credibility of Witnesses**: Whether the inconsistencies in witness testimonies undermine the prosecution’s case.
2. **Evidence of Sexual Assault and Rape**: Whether the medical findings corroborate the victim’s allegations.
3. **Modifications of Sentences and Damages**: Whether the penalties and damages awarded by the lower courts were appropriate.
### Court’s Decision:
– **Credibility of Witnesses**:
– The Supreme Court found that the inconsistencies claimed by the defense did not negate the overall credibility of the witnesses. The court emphasized that minor inconsistencies are common in testimonies involving traumatic events.
– **Evidence of Sexual Assault and Rape**:
– The victim’s testimony was corroborated by her sister “YYY” and the medical findings of Dr. Roy Camarillo, which identified deep healed lacerations consistent with the alleged sexual acts.
– **Modifications of Sentences and Damages**:
– The penalties were adjusted to conform to prevailing jurisprudence:
– For the two counts of qualified rape (Criminal Case Nos. 13941-06-C and 13942-06-C), the exemplary damages, civil indemnity, and moral damages were increased to P100,000.00 each.
– For the two counts of rape by sexual assault (Criminal Case Nos. 13940-06-C and 13943-06-C), the sentence was modified to eight (8) years and one (1) day of prision mayor as minimum to seventeen (17) years and four (4) months of reclusion temporal as maximum. The civil indemnity and moral damages were modified to P30,000.00 each, with exemplary damages at P30,000.00 for each count.
– All damages awarded shall earn interest at the rate of 6% per annum from the date of finality of judgment until fully paid.
### Doctrine:
– **Inconsistencies in the Testimony of Rape Victims**: Minor inconsistencies do not undermine credibility; traumatic events often lead to inaccuracies in details.
– **Corroboration of Victim’s Testimony**: Medical findings, particularly healed lacerations, are strong evidence supporting claims of rape.
### Class Notes:
– **Key Elements/Concepts**:
– **Sexual Assault (Article 266-A, Paragraph 2, Revised Penal Code)**: Inserting finger into genitalia against will.
– **Rape by Sexual Assault**: Consistent with elements of force, threat, and intimidation.
– **Carnal Knowledge (Qualified Rape)**: Presence of aggravating circumstances like minority and relationship (parent to child).
– **Critical Statutory Provisions**:
– **Revised Penal Code, Article 266-A**: Defines and penalizes rape and sexual assault.
– **Civil Code Provisions on Damages**: Civil indemnity, moral, and exemplary damages consistent with compensatory functions for victims.
– **Application**:
– Analyzing witness credibility considering psychological impact.
– Importance of medical corroboration in sexual crimes.
– Judicious adjustment of penalties and damages to reflect jurisprudential standards.
### Historical Background:
The case underlines increasing judicial sensitivity and strict standards for sexual offenses to protect minors, reflecting legislative trends in providing heightened protection and support for victims of sexual abuse, particularly children. This indicates the evolving landscape of judicial prudence in the Philippines, aiming to balance stringent legal standards with compassionate victim support.
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