When the elements of statutory rape (victim below the statutory age) concur with special qualifying aggravating circumstances under Article 266-B of the Revised Penal Code (such as minority and relationship, victim below 7 years old, or offender's knowledge of victim's mental disability), the proper designation of the crime is "Qualified Rape of a Minor," not "qualified statutory rape"; the special qualifying circumstance absorbs the inherent circumstance of the victim's age, elevating the crime to qualified rape.

The case arose from charges filed against the accused, ABC260708, for committing rape through carnal knowledge and rape through sexual assault (oral rape) against his own daughter, AAA260708, who was eight years old at the time of the incidents in March 2015.

• The accused, ABC260708, was charged in two separate Informations for raping his 7-year-old daughter, AAA260708, on March 17, 2015, in Cagayan province.
• Criminal Case No. 17006 alleged rape by sexual intercourse using force, threat, and intimidation, aggravated by the victim's minority (7 years old) and the father-daughter relationship.
• Criminal Case No. 17007 alleged rape by sexual assault through inserting his penis into the victim's mouth, under the same circumstances and aggravations.
• The victim, AAA260708 (who was actually 8 years old at the time, born February 6, 2007, but testified she was 8 years old during trial), testified that her father called her into their room, removed her underwear, made her lie on the bed, laid on top of her, spread her legs, and inserted his penis into her vagina, causing pain.
• AAA260708 further testified that after the vaginal rape, while she was standing, her father inserted his penis into her mouth.
• The accused threatened to kill AAA260708 if she reported the incident.
• The victim's older sister, BBB260708, corroborated parts of the incident, testifying she saw her sister without undergarments and her father clad only in briefs inside the house after entering through an unfinished window because the door was locked.
• A medical report dated March 18, 2015, revealed fresh hymenal laceration incurred within 24 hours from penetration.
• A photocopy of the victim's birth certificate was presented, showing her date of birth and indicating the accused as her father.
• The accused denied the charges, claiming he only bathed his daughter on the date in question and was wearing a sando and underwear when the older sister arrived.
• The accused admitted during trial that the victim was his daughter.
• The RTC found the victim's testimony credible and convicted the accused, noting the victim was 8 years old at the time of the crime, not 7 as alleged in the Informations.
• The CA affirmed the conviction but termed the first crime "qualified statutory rape" and modified the penalty for the sexual assault charge.

• As plaintiff-appellee, the People argued that the prosecution successfully proved the accused's guilt beyond reasonable doubt through the victim's positive, categorical, and credible testimony.
• The People argued that the victim's testimony was corroborated by her sister's testimony and the medical findings of fresh hymenal laceration.
• The People contended that the minority of the victim (8 years old) and the father-daughter relationship were sufficiently established through the birth certificate (admissible as secondary evidence) and the accused's own judicial admission.
• The People maintained that the accused's uncorroborated denial is a weak defense that cannot overcome the positive identification and testimony of the victim.
• The People asserted that minor inconsistencies, such as the exact date of the crime (March 15 vs. March 17), do not detract from the victim's credibility, especially given her tender age and the trauma experienced.

• The accused-appellant, ABC260708, argued that the prosecution failed to establish his guilt beyond reasonable doubt.
• The accused-appellant contended that the testimony of the victim, AAA260708, was incredible and unbelievable.
• The accused-appellant relied on his defense of denial.

• Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for rape and rape through sexual assault based on the evidence presented.
• What is the proper taxonomic designation or nomenclature of the crime when the elements of both statutory rape (victim is below the statutory age) and qualified rape (presence of special qualifying circumstances like minority and relationship, or victim below 7 years old) are present?

• The Supreme Court DENIED the appeal and AFFIRMED the conviction of ABC260708 with modifications to the designation of the crime in Criminal Case No. 17006 and the awarded damages.
• The Court found the victim's testimony straightforward, unwavering, and credible, corroborated by her sister's testimony and the medical evidence of fresh hymenal laceration, sufficient to establish guilt beyond reasonable doubt.
• The Court upheld the admission of the photocopy of the birth certificate under the exception to the Best Evidence Rule for public records (Rule 130, Sec 3(d)), especially since the defense did not dispute its contents. The accused's judicial admission of paternity further established the relationship.
• The Court extensively discussed the nature, classification, and effects of aggravating circumstances (generic, specific, qualifying, inherent, special, special qualifying) in criminal law.
• The Court clarified that the victim being below the statutory age (under 12, now under 16 per RA 11648) is an inherent circumstance in statutory rape, merely dispensing with proof of force/intimidation.
• The Court ruled that circumstances listed in Article 266-B, such as the twin circumstances of minority (under 18) and relationship (parent, etc.), or the victim being below 7 years old, are special qualifying aggravating circumstances that change the nature of the crime and elevate the penalty.
• The Court held that when such special qualifying aggravating circumstances are present alongside the victim being below the statutory age, the special qualifying circumstances absorb the inherent circumstance of age. The crime is elevated to Qualified Rape.
• The Court explicitly abandoned the nomenclature "qualified statutory rape" used in prior cases (like Bantolo, Reyes, Laceste, Deliola, etc.), finding it inconsistent with criminal law principles as a circumstance cannot be both inherent and qualifying/aggravating simultaneously.
• The Court established that the correct nomenclature is "Qualified Rape of a Minor" when special qualifying aggravating circumstances under Art. 266-B coexist with the victim being below the statutory age.
• Applying this, the Court found ABC260708 guilty of "Qualified Rape of a Minor" in Criminal Case No. 17006 (due to minority and relationship) and guilty of Sexual Assault under Art. 266-A(2) in relation to RA 7610, Sec 5(b) in Criminal Case No. 17007.
• The penalty of reclusion perpetua without parole for qualified rape was affirmed. The penalty for sexual assault was also affirmed.
• The civil indemnity, moral damages, and exemplary damages in Criminal Case No. 17006 (Qualified Rape of a Minor) were increased from PHP 100,000.00 each to PHP 150,000.00 each. Damages in Criminal Case No. 17007 were affirmed.

• Credibility of Witnesses: The assessment of the truthfulness and accuracy of a witness's testimony. The Court reiterated the doctrine that trial courts are in the best position to assess witness credibility, and their findings are generally accorded great respect, especially when affirmed by the CA. It was applied to uphold the victim's testimony despite minor inconsistencies and the accused's denial.
• Best Evidence Rule (Secondary Evidence Exception): The rule requires the original document to be produced when its contents are the subject of inquiry, but allows secondary evidence (like photocopies) under certain exceptions, including when the original is a public record in the custody of a public officer. Applied to justify the admission of the photocopy of the victim's birth certificate to prove her age and relationship with the accused, as the original is a public record with the civil registrar.
• Judicial Admission: An admission, verbal or written, made by a party in the course of the proceedings in the same case, which does not require proof (Rule 129, Sec 4). The accused's admission during trial that the victim was his daughter was considered a judicial admission, dispensing with further proof of their relationship.
• Statutory Construction (Penal Laws): Principles governing the interpretation of criminal statutes, generally requiring strict construction in favor of the accused but also considering legislative intent. Discussed in relation to the legislative prerogative in defining crimes and penalties, and the Court's role in providing proper nomenclature consistent with the law when none is specified, avoiding judicial legislation.
• Classification of Aggravating Circumstances: The categorization of circumstances that increase criminal liability (generic, specific, qualifying, inherent, special, special qualifying), each having different effects on the penalty and designation of the crime. The Court provided a detailed analysis of these classifications to differentiate statutory rape from qualified rape and to determine the correct legal effect when circumstances related to both are present.
• Absorption of Aggravating Circumstances: A rule providing that once a circumstance is used to qualify a crime, it cannot be used again as a generic aggravating circumstance, and that qualifying or special circumstances absorb inherent or generic ones. The Court applied this to rule that the special qualifying circumstances (minority and relationship) absorb the inherent circumstance (victim's age below statutory threshold), thus designating the crime as Qualified Rape.
• Statutory Rape: Rape committed against a victim below a specific statutory age (formerly 12, now 16 under RA 11648), where lack of consent is conclusively presumed, and force/intimidation need not be proven. Defined and distinguished from qualified rape as the baseline crime when only the age element is present without special qualifying circumstances.
• Qualified Rape: Rape committed under circumstances enumerated in Article 266-B of the RPC (formerly Art. 335 as amended by RA 7659, now Art. 266-B via RA 8353), which increase the penalty (formerly death, now reclusion perpetua without parole). Identified as the correct designation when special qualifying circumstances (like minority and relationship) are present, even if the victim is also below the statutory age for statutory rape.
• Abandonment of Doctrine/Nomenclature: The act by the Supreme Court of overturning or discontinuing the use of a previously established legal rule or term found to be erroneous or inconsistent with legal principles. The Court explicitly abandoned the term "qualified statutory rape," overruling prior jurisprudence that used this conflicting nomenclature.

• "The meticulous study of a crime begins with the understanding of its definition, nature, and penalty, and ends with an accurate nomenclature or designation of the offense."
• "The Court categorically rules that the term qualified statutory rape is not consistent with the basic precepts of criminal law in defining and treating the nature of crimes, and hereby abandons the set of case law adopting such nomenclature."
• "Corollary, the victim being below the statutory age... cannot be appreciated as an inherent and special qualifying aggravating circumstance at the same time."
• "As such, the proper designation of the crime must be qualified rape and not qualified statutory rape. The Court affirms its previous rulings that the presence of special qualifying circumstances under Article 266-B of the RPC raises the crime of statutory rape to qualified rape."
• Guideline 1: "The crime shall be denominated as QUALIFIED RAPE of a minor and not qualified statutory rape if any of the special qualifying aggravating circumstances is present..."

• People v. Cayabyab (2005): Cited to support the admissibility of a photocopy of a birth certificate as secondary evidence to prove the victim's age, as the original is a public record.
• People v. Tipay (2000): Cited for the principle that the minority of a victim of tender age can be manifest, allowing the court to take judicial notice, and that presentation of a birth certificate is not the sole means to prove age.
• People v. Besmonte (2014) & People v. Pacayra (2017): Cited as examples of jurisprudence correctly holding that the presence of qualifying circumstances (minority and relationship) raises statutory rape to qualified rape.
• People v. Tulagan (2019): Cited regarding the nomenclature for sexual assault involving a minor under RA 7610. The Court clarified a statement attributed to Tulagan in the Orgula case concerning "qualified statutory rape," noting Tulagan actually distinguished statutory rape and qualified rape properly.
• People v. Bantolo (2014), People v. Reyes (2014), People v. Laceste (2014), People v. Deliola (2016), People v. Gaa (2017), People v. Orgula (2020), et al.: Cited as part of the conflicting jurisprudence that incorrectly used or adopted the term "qualified statutory rape," which the current decision explicitly abandons.
• People v. Jugueta (2016): Cited as the prevailing jurisprudence regarding the amounts of damages awarded in rape cases, which guided the modification of damages in this case.
• People v. Garcia (1997) & People v. Lomaque (2013): Cited for characterizing the circumstances under RA 7659 (now in Art. 266-B) as "special qualifying aggravating circumstances."
• Dulla v. CA (2000): Cited in relation to the application of the Indeterminate Sentence Law for the sexual assault penalty.

• Revised Penal Code (RPC), Article 266-A: Defines Rape, including rape by sexual intercourse (par. 1) and rape by sexual assault (par. 2), and circumstances like victim under 12/16 (statutory rape) or demented (1(d)).
• RPC, Article 266-B: Enumerates penalties and the 10 aggravating/qualifying circumstances for rape that warrant the imposition of the highest penalty (formerly death, now reclusion perpetua without parole), including minority (under 18) + relationship (par. 1), victim below 7 years old (par. 5), offender's knowledge of victim's mental disability (par. 10).
• RPC, Article 335 (Old Code/As amended by RA 7659): Previous provision defining rape and its qualifying circumstances before RA 8353.
• RPC, Article 14: Enumerates generic aggravating circumstances.
• RPC, Articles 48, 49, 50-57, 62, 64, 69, 71: Provisions related to complex crimes, penalties for principals, accomplices, accessories, application of penalties with aggravating/mitigating circumstances, privileged mitigating circumstances, and scale of penalties.
• Republic Act No. 7610 (Special Protection of Children Act), Section 5(b): Cited in relation to the sexual assault charge (Crim. Case No. 17007), likely qualifying the act as child abuse.
• Republic Act No. 7610, Section 31(f): Basis for imposing a fine in the sexual assault conviction.
• Republic Act No. 8353 (Anti-Rape Law of 1997): Introduced Articles 266-A to 266-D into the RPC, reclassifying rape as a crime against persons.
• Republic Act No. 7659 (Heinous Crimes Law): Amended Art. 335 RPC, imposing death penalty for rape with certain circumstances (now found in Art. 266-B).
• Republic Act No. 9346: Prohibits the imposition of the death penalty, mandating reclusion perpetua or life imprisonment instead.
• Republic Act No. 11648 (2022): Amended RPC Art. 266-A(1)(d), raising the age for statutory rape from under 12 to under 16 years. (Noted as not applicable since crime occurred in 2015).
• Revised Rules of Court, Rule 130, Section 3(d): Exception to the Best Evidence Rule regarding public records.
• Revised Rules of Court, Rule 129, Section 4: Rule on Judicial Admissions.
• Supreme Court Amended Administrative Circular No. 83-2015: Protocol on using fictitious names/initials for parties in sensitive cases.