People of the Philippines v. Divinagracia, G.R. No. 207765 (2017)
The Regional Trial Court of Mandaue City and the Court of Appeals found the appellant, guilty of statutory rape of his eight-year-old daughter and acts of lasciviousness against his nine-year-old daughter. He appealed, arguing that the prosecutor had not sufficiently established his guilt and that the victims were not credible witnesses because their testimonies had inconsistencies on when they told others about the abuse. The Supreme Court found that these inconsistencies did not relate to the elements of the crime, nor did they diminish the credibility of the victims. In fact, the recognized rule is that the higher courts shall respect the fact-findings and evaluation of witness credibility of the lower courts, unless either party demonstrates that the trial court may have overlooked, misunderstood, or misapplied any fact or circumstance of weight and substance. The Supreme Court refused to find that the failure of one of the victims to immediately confide in others had impacted her credibility. The Court also reiterated that the credible testimony of the victim is sufficient to establish the accused’s guilt on its own. With respect to damages, the Court overruled the lower court's holding that an award of damages would be a miscarriage of justice because the defendant-father was a compulsory heir to his daughters. Instead, the Court awarded the eight-year-old victim a total of PHP 300,000.00 in damages, and the nine-year-old victim a total of PHP 70,000.00. The Court also affirmed the lower court's sentence of 20 to 40 years in prison for the crime of rape, as well as 12 to 20 years for the crime of lasciviousness.
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Year
- 2018
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