Case Digest (G.R. No. 126124)
Facts:
People of the Philippines v. Zaldy P. Padilla, G.R. No. 126124, January 20, 1999, Supreme Court En Banc, Mendoza, J., writing for the Court. For review is a decision of the Regional Trial Court, Branch XLV, Urdaneta City, Pangasinan, convicting accused-appellant Zaldy P. Padilla of rape and sentencing him to death; the trial court also ordered indemnity of P50,000.00 and costs.On April 27, 1995, the 13‑year‑old mentally retarded victim, Maria Aurora B. Bautista, was at a neighbor’s calamansi (citrus) orchard when Padilla, then 26 years old and employed as a farmhand by the orchard owner, accosted her. Armed with a scythe and a knife, Padilla allegedly forced Maria Aurora to undress, made her lie on the grass, threatened her and had sexual intercourse with her. The victim reported the incident to her father the same evening and was examined by Dr. Luisa F. Cayabyab at Governor Teofilo Sison Memorial Hospital; the physician found fresh lacerations of the hymen consistent with penile penetration.
On May 2, 1995, Maria Aurora’s father filed a complaint in the Municipal Circuit Trial Court, Pozorrubio, Pangasinan; after preliminary investigation the case was referred to the Office of the Provincial Prosecutor, which on May 26, 1995 filed an information for rape in the Regional Trial Court, Branch XLV, Urdaneta City. Padilla pleaded not guilty and trial was held with hearings on December 6, 1995; January 23, 1996; January 31, 1996; February 22, 1996; and March 27, 1996. The trial court rendered judgment finding Padilla guilty of rape with attendant circumstances (use of a deadly weapon, disregard of respect due to the victim’s age, and abuse of superior strength) and sentenced him to death; it also ordered indemnity of P50,000.00.
Padilla appealed to the Supreme Court contesting, as his lone assignmen...(Subscriber-Only)
Issues:
- Was the trial court's admission of the alleged victim’s testimony proper given her mental retardation; i.e., was she competent to testify?
- Did the evidence establish Padilla’s guilt beyond reasonable doubt, including identity and use of force or intimidation?
- Were the aggravating circumstances properly appreciated and, if not, what is the proper penalty?
- Is the offended party entitled to moral damages in addition to th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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