Case Digest (G.R. No. 202978)
Facts:
People of the Philippines v. Victor P. Padit, G.R. No. 202978, February 01, 2016, Supreme Court Third Division, Peralta, J., writing for the Court. The prosecution (the People of the Philippines) charged accused-appellant Victor P. Padit with rape for acts alleged to have occurred on May 5, 2006 against AAA, a four-year-old girl.On the morning of May 5, 2006, AAA left home to buy bread, was called by accused-appellant (their neighbor, whom AAA called "Lolo Victor"), taken into his house, brought upstairs, made to lie down, had her short pants removed, and was allegedly subjected to the accused rubbing his penis against her vagina, covering her mouth and threatening her with a knife. AAA later told her mother about the incident; a medical examination on May 8, 2006 recorded a slight hymenal abrasion. AAA’s parents filed a barangay complaint and thereafter a criminal complaint with the prosecutor; an Information dated August 2, 2006 charged Padit with rape (naming Article 335, Revised Penal Code).
At pre-trial the parties stipulated that the victim was four years old, that the accused was the person charged, and that the families were neighbors. At trial the defense denied the charge and presented Padit’s wife who testified that she was with him at the time. On March 3, 2008, the Regional Trial Court (RTC), Branch 3, Guiuan, Eastern Samar, convicted Padit of rape, sentenced him to reclusion perpetua and ordered civil indemnity and moral damages (P75,000 each).
Padit appealed to the Court of Appeals (CA). On July 19, 2011, the CA affirmed with modification, adding exemplary damages of P30,000. Padit filed a Notice of Appeal to the Supreme Court; the CA elevated the records and this Court received supplemental filings and manifestations including the Office of t...(Subscriber-Only)
Issues:
- Does the erroneous designation of the penal statute in the Information (Article 335, RPC) vitiate the Information?
- Was the prosecution able to prove beyond reasonable doubt that accused-appellant committed rape (statutory rape of a child under twelve)?
- Was the testimony of the victim’s mother inadmissible hearsay and, if so, did it render the conviction infirm?
- What is the proper penalty and damages given the victim’s age and current law (including the effect...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)