Case Digest (G. R. No. L-23080)
Facts:
People of the Philippines v. Henry Padero, G.R. No. 106274, September 28, 1993, Supreme Court First Division, Davide, Jr., J., writing for the Court.On 21 January 1992, a complaint was filed in Branch 45, Regional Trial Court (RTC) of Bais City (Criminal Case No. 741‑B) by Jocelyn Cadelina, then 16 years old, charging her uncle‑in‑law Henry Padero with rape allegedly committed on 31 August 1991 by force and intimidation with a knife. An arrest warrant issued 21 January 1992 was served on 4 March 1992; no bail was recommended. At arraignment on 13 March 1992 the accused pleaded not guilty and the case was set for continuous trial.
At trial the prosecution presented the complainant and Cherryl Palacios in its case‑in‑chief and called Clara Cadelina, Rev. Lemuel Felecio, and Damiana Cadelina on rebuttal. The defense put the accused on the stand and offered Loreta Samane, Elsa Garcia, Macrina Padero (the accused’s mother), and Marietta Padero (his wife). The RTC, in a decision promulgated 22 June 1992, convicted Henry Padero of rape, sentenced him to reclusion perpetua and ordered indemnity of P30,000, finding the complainant credible and describing the defense witnesses as inconsistent.
The accused seasonably appealed to the Supreme Court, assigning errors challenging the trial court’s credibility findings and asserting that the sexual relations were consensual. On appeal the accused argued among other things that the complainant’s delayed reporting, the absence of evident resistance, the lack of corroboration of the alleged knife threat, and numerous witnesses and fa...(Subscriber-Only)
Issues:
- May the Supreme Court overturn the trial court’s credibility findings in a rape prosecution?
- Did the prosecution prove beyond reasonable doubt that the accused had carnal knowledge of the complainant by force or intimidation as defined in Article 335(1) of the Revised Penal Code?
- Did the prosecution’s failure to recall the complainant to rebut the new facts asserted by the accused constitute pre...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)