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PEOPLE v. XXX

FACTS:

AAA, the daughter of the accused-appellant, testified that her father raped her inside their bedroom. She explained that she did not resist because she was terrified of him and mentioned that her father had threatened to kill her mother if she told anyone about the assault. AAA's mother corroborated her daughter's testimony and mentioned that AAA had disclosed the repeated abuse she suffered at the hands of her father. The prosecution also presented AAA's birth certificate and medical examination reports that confirmed her age and the presence of injuries to her genital area. AAA herself testified about the details of the rape incident and expressed the fear and pain she experienced. The defense claimed that the accused-appellant was at home with his sons, and that AAA and her sibling were at their neighbor's house on the date of the alleged rape. The accused-appellant denied the rape allegations and argued that AAA's motive was to seek revenge. The RTC found the accused-appellant guilty of incestuous rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction, holding that the prosecution established AAA's minority and the identity of her father as the perpetrator.

The accused-appellant filed an appeal before the Supreme Court, arguing that AAA's testimony should not be fully believed due to doubts about her motive and emphasizing her failure to respond to certain questions during the trial. He also disputed the prosecution's failure to prove carnal knowledge beyond reasonable doubt and claimed that the physical evidence did not corroborate AAA's testimony. The prosecution countered these arguments by stating that AAA's straightforward testimony was supported by the witness, PCI Baluyot, who found physical signs of trauma during the examination. They argued that even touching the labia is enough to prove rape, even if the hymen remains intact. The prosecution also emphasized the trial court's evaluation of the credibility of a child-witness, considering their opportunity to observe the testimonies.

ISSUES:

  1. Whether the incorrect designation of the crime as Statutory Rape instead of Qualified Rape in the Information violates the accused's right to be informed of the nature and cause of the accusation against him.

  2. Whether the recantations made by the victim and her mother should be given weight and considered as evidence.

  3. Whether the testimonies of the prosecution witnesses should be favored given the trial court's assessment of the evidence.

RULING:

  1. The incorrect designation of the crime as Statutory Rape instead of Qualified Rape in the Information does not violate the accused's right to be informed of the nature and cause of the accusation against him. The designation of the offense in the Information is not controlling, but rather the actual facts recited in the Information constituting the crime charged. The Information clearly and accurately alleged the elements of the offense charged, and these allegations were adequately proven during trial. Hence, the incorrect designation of the crime is immaterial.

  2. The Court held that the recantations made by the victim and her mother should not be given weight as they were presented two years after the filing of the case and after the accused had already completed his testimony. The Court questioned the credibility of the recantations given the circumstances surrounding their filing and noted that the victim's testimony was clear, consistent, and did not show signs of rehearsal or coercion. The Court emphasized that recantations are viewed unfavorably in rape cases and are thoroughly examined before being given any weight. The trial court did not consider these recantations before rendering its ruling.

  3. The Court ruled that the testimonies of the prosecution witnesses should be favored, as the trial court placed more confidence in them. The Court reiterated that questions on the credibility of witnesses are best addressed to the trial court, which has the unique position to observe the witnesses' deportment on the stand while testifying. Absent any badge of error on the part of the trial court in assessing the evidence, the Court saw no reason to depart from its findings that the accused had committed the crime of rape.

PRINCIPLES:

  • The elements of Qualified Rape are sexual congress with a woman done by force and without consent, where the victim is under eighteen years old at the time of the rape, and the offender is a parent of the victim. The offender's moral ascendancy or influence over the victim substitutes for violence and intimidation in cases where the offender is the victim's father.

  • The designation of the offense in the Information is not controlling. What is important is that the facts recited in the Information clearly and accurately allege the elements of the crime charged. The purpose of requiring the elements of a crime to be set out in the Information is to enable the accused to suitably prepare his defense.

  • Recantations are viewed unfavorably in rape cases and are thoroughly examined before being given weight.

  • Testimonies of child victims are given full weight and credit, as youth and immaturity are generally badges of truth and sincerity.

  • Questions on the credibility of witnesses are best addressed to the trial court, which has the unique position to observe the witnesses' deportment on the stand while testifying.