G.R. No. 157013 - Macalintal vs. Commission on Elections

Petitioner Elmer Padua y Garin a.k.a. "Eming" was charged with rape by sexual assault under Article 266-A, par. 2 of the Revised Penal Code (RPC) for an incident that occurred on the morning of June 4, 2014.
The victim, AAA, was a three-year-old minor at the time of the alleged offense.

On June 4, 2014, AAA went to play at the house of neighbors CCC and DDD after school, with permission from her mother BBB.
After playing, outside CCC's house, Elmer called AAA to follow him to his house located about seven meters away.
At Elmer's house, he forcibly removed AAA's leggings and panties and inserted his finger into her vagina against her will.
AAA screamed in pain, and Elmer covered her mouth to silence her.
Hearing AAA’s mother calling her, Elmer put back AAA’s leggings. AAA ran to her mother but did not immediately disclose the incident.
Two days later, AAA told her mother about the assault.

BBB searched for AAA, finding her crying outside Elmer's or CCC's house.
BBB noticed AAA’s leggings crumpled and that AAA was not wearing underwear.
AAA then revealed the assault to her mother.
The incident was reported to the barangay chairperson, who called police assistance.

At the police station, AAA gave a sworn statement with her mother assisting.
Police officers arrested Elmer based on AAA’s identification.
Medical examination by Dr. Roa Joy De Guzman showed signs of sexual abuse, including erythematous and hymenal laceration at 3:00 o’clock, corroborating AAA’s claims.

At arraignment, Elmer pleaded not guilty.
During pretrial, prosecution and defense stipulated on Elmer’s identity, neighbor relationship with AAA, and AAA’s age.
Prosecution presented testimonies from AAA and BBB and introduced documentary evidence including the birth certificate and medico-legal certificate.
Elmer and his mother Carmelita testified, denying any sexual assault and asserting an alibi; they claimed Elmer was occupied with chores during the incident time.
Defense argued inconsistencies in the testimonies and challenged the reliability of AAA’s recollections due to infantile amnesia.

The RTC found Elmer guilty beyond reasonable doubt of rape by sexual assault and ordered him to pay civil and moral damages.
The CA affirmed the RTC's judgment but modified the damages awarded and imposed a fine.
The Supreme Court denied Elmer’s petition and modified his conviction from rape by sexual assault to sexual assault under Article 266-A(2) RPC, relating to Republic Act 7610 due to the victim’s age.

Whether Elmer Padua y Garin is guilty beyond reasonable doubt of rape by sexual assault or sexual assault under Article 266-A, paragraph 2 of the RPC, in relation to Republic Act 7610.

Whether the testimony of the child-victim AAA is reliable and credible despite alleged inconsistencies and the theory of infantile amnesia.

Whether the inconsistencies in the witnesses' testimonies affect the veracity and sufficiency of evidence to convict.

Proper designation of the offense and the corresponding penalty given the victim’s age and the nature of the act.