- Petitioner
- People
- Respondent
- XXX
- Citation
- G.R. No. 254254
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Gaerlan, J.
- Decided
- February 16, 2022
Summary
The Supreme Court affirmed the conviction of XXX for qualified rape by carnal knowledge against his 13-year-old daughter in 2009, imposing reclusion perpetua and P100,000 each for civil indemnity, moral and exemplary damages. However, the Court modified his conviction for the March 2012 incident from qualified rape by sexual assault to Lascivious Conduct under R.A. No. 7610, following the Tulagan doctrine that rape by sexual assault against minors aged 12-18 should be prosecuted under the child protection law. The Court sentenced him to reclusion perpetua for this charge as well, with P75,000 each for damages plus P15,000 fine. The Court rejected XXX's claim that the duplicitous Information was defective, ruling he waived this objection by failing to challenge it before trial. The decision emphasized that a child victim's testimony alone, if credible, suffices for conviction, and that medical evidence is not indispensable in rape prosecutions.