G.R. No. 126124 - People vs. Padilla

On April 27, 1995, Maria Aurora B. Bautista, a 13-year-old girl with mental retardation, was at a citrus farm owned by Jose Sagun in Barangay Bobonan East, Municipality of Pozorrubio, Pangasinan.
Accused-appellant Zaldy P. Padilla, aged 26, a married man and a farmhand employed by Sagun, approached her armed with a scythe and a knife.

Padilla accosted the minor, forcibly undressing her and compelling her to lie on the grass.
He then proceeded to rape her, using force and intimidation while uttering assaultive phrases.

Later that day, Maria Aurora reported the incident to her father, Engracio L. Bautista, who subsequently took her to the Governor Teofilo Sison Memorial Hospital.
Dr. Luisa F. Cayabyab examined her and noted fresh lacerations in her hymen, indicative of forcible sexual penetration.
The complaint was formally filed on May 2, 1995 at the Municipal Circuit Trial Court in Pozorrubio, and a preliminary investigation established probable cause against Padilla.

The case was referred to the Office of the Provincial Prosecutor in Urdaneta City, which on May 26, 1995, filed an information for rape in the Regional Trial Court, Branch XLV.
Accused-appellant Padilla was arraigned and pleaded not guilty, with hearings conducted on several dates (December 6, 1995; January 23, January 31, February 22, and March 27, 1996).
On May 8, 1996, the trial court rendered a judgment finding Padilla guilty of rape and sentenced him initially to death, as well as ordering him to pay P50,000.00 as indemnity to the victim.

The victim's testimony in open court detailed the events, including her recognition and identification of Padilla as the assailant, and recounted the threat and use of a deadly weapon during the assault.
Despite some minor inconsistencies regarding whether a knife or scythe was used at a particular moment, the overall narrative was deemed credible, especially given the trauma of her experience.
Additional corroboration came from the medical certificate issued by Dr. Cayabyab, which referenced fresh lacerations consistent with the reported assault.

The accused-appellant raised an assignment of error regarding the admissibility of the victim’s testimony, contending that her mental handicap rendered her incompetent to testify.
He also advanced an alibi, asserting that at the time of the incident he was in the hut with two other farmhands, an assertion supported by one of them, Santiago Sagun.
The trial court, however, rejected both the competency challenge—citing that mental retardation alone does not disqualify one from providing coherent testimony—and the alibi, noting the proximity of the hut to the scene of the crime.

Whether the mental retardation of Maria Aurora B. Bautista affected her capacity to perceive and relate the events accurately.
Whether her testimony should be excluded on the ground of incompetence due to her mental condition.

Whether the accused-appellant’s claim of being in the hut with farmhands at the time of the rape could counter the identity evidence provided by the victim.
Whether the proximity of the alleged alibi location to the scene of the crime weakened the defense’s argument.

Whether the use of a deadly weapon (knife/scythe) and the application of force and intimidation in the commission of the crime were adequately supported by the evidence.
Whether the trial court erred in allowing the victim’s testimony with minor inconsistencies given her traumatic experience.

Whether the trial court was correct in considering aggravating circumstances such as the disregard of respect due to the victim’s age and abuse of superior strength.
Whether these aggravating circumstances could be sustained given that rape was, at the time, classified as a crime against chastity and not as a crime against persons and honor.