Facts:
1. **July 23, 2015**: Three Informations were filed charging XXX with three counts of Rape against his daughters, AAA and BBB.
2. **Informations**:
– **Criminal Case No. 3068-2015**: Incident on March 7, 2015 – XXX raped AAA, 14 years old, using force, threat, and intimidation.
– **Criminal Case No. 3069-2015**: Incident on March 9, 2015 – XXX raped AAA again.
– **Criminal Case No. 3070-2015**: Incident on March 13, 2015 – XXX raped BBB, 11 years old, using similar methods.
3. **Arraignment**: XXX pleaded not guilty to all charges. Pre-trial and trial on the merits followed.
**Prosecution’s Version**:
– **March 7, 2015**: At 10:00 PM, XXX raped AAA while she was sleeping with her siblings, threatening to kill her if she resisted.
– **March 9, 2015**: At 7:00 AM, XXX raped AAA again after sending her siblings to bathe in the river.
– **March 13, 2015**: XXX raped BBB inside their house when her mother and older sister were away.
– **March 16, 2015**: CCC, the older sister of AAA and BBB, reported the incidents to the Barangay Chairman and MSWDO after AAA revealed the assaults. Medical examinations confirmed hymenal lacerations on AAA and BBB.
**Defense’s Version**:
– **Denial**: XXX denied the accusations, alleging that CCC, who harbored resentment against him, conspired with AAA and BBB to maliciously frame him due to family disputes.
– **Alibi**: XXX claimed he was away to settle debts when he learned about the charges and surrendered voluntarily to the police.
**Procedural Posture**:
– **Regional Trial Court (RTC)**: Found XXX guilty beyond reasonable doubt of three counts of incestuous rape, imposing reclusion perpetua without parole and monetary damages to the victims.
– **Court of Appeals (CA)**: Affirmed the RTC’s decision, rejecting XXX’s arguments on the alleged inconsistencies of the victims’ testimonies.
Issues:
1. Whether the inconsistent statements of AAA and BBB undermine their credibility and affect the prosecution’s case.
2. Whether the prosecution proved XXX’s guilt beyond reasonable doubt.
Court’s Decision:
1. **Inconsistency in Witness Testimony**:
– **Supreme Court Analysis**: Minor inconsistencies are expected, especially from minors recounting traumatic experiences. These do not detract from the overall credibility of the victims’ testimonies, which were deemed convincing and straightforward.
– **Resolution**: The Court upheld that inconsistencies in non-material details do not invalidate the substance and truth of the testimonies.
2. **Proof Beyond Reasonable Doubt**:
– **Qualified Rape Elements**:
– Sexual congress with a woman.
– Use of force, threat, intimidation.
– Victim under 18 years old.
– Offender is a parent of the victim.
– **Court’s Assessment**: All elements were met. The victims’ minority was proven by their birth certificates. The medical evidence corroborated the sexual assault. The victims’ testimony convincingly identified XXX, their biological father, as the perpetrator.
– **Resolution**: Affirmed XXX’s guilt and the corresponding penalties for qualified statutory rape.
Doctrine:
1. **Minor Inconsistencies**: Do not affect the credibility of the testimony when the victim is a minor recounting traumatic experiences.
2. **Qualified Rape**: Establishes that rape committed by a parent on a minor child carries severe penalties, including reclusion perpetua.
Class Notes:
1. **Qualified Rape**:
– Sexual congress by force.
– Victim under 18.
– Offender is a parent.
– **Statutes**:
– Article 266-A(1)(a) and Article 266-B of the Revised Penal Code.
2. **Evidence Evaluation**:
– Credibility of witness testimony.
– Medical corroboration.
– Factual findings by the trial court given deference unless glaring errors are present.
3. **Psychological Understanding**:
– Child Sexual Abuse Accommodation Syndrome (CSAAS) explains the behavior of child victims of sexual abuse.
Historical Background:
– **Cultural Context**: The case illustrates the challenges in prosecuting incestuous rape in a cultural setting where family honor and dynamics often complicate the disclosure and prosecution of such crimes.
– **Legislative Evolution**: Reflects the Philippines’ legal framework’s ongoing development to provide better protection for minors and enhance penalties for sexual crimes against them. The enactment of RA 8353 reclassifies rape as a crime against persons, emphasizing the seriousness of sexual offenses within the familial context.
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