G.R. No. 202978 - People vs. Padit

On May 5, 2006, in Guiuan, Eastern Samar, the four-year-old victim, designated as AAA, was initially playing inside her house while her mother attended to her younger brother.
AAA left the house to buy bread and was intercepted by her neighbor, Victor P. Padit—whom she familiarly calls “Lolo Victor” and who is also her mother's uncle.

Accused-appellant invited AAA into his house and allowed her to play.
He then took her upstairs, caused her to lie down, removed her short pants, and proceeded to remove his own short pants.
He rubbed his penis against her vagina, an act during which AAA experienced pain and was rendered helpless when he covered her mouth with his hand to stifle her cries.
He threatened to harm her with a knife should she disclose the incident, thereby employing force and intimidation.

AAA’s mother, noticing her daughter’s prolonged absence while about to serve lunch, went around the neighborhood calling for her.
At one point, she encountered accused-appellant in his yard, who casually mentioned that AAA was inside “watching him weave baskets.”
Once AAA was brought outside, her mother questioned her, leading AAA to disclose the molestation incident.
Despite accused-appellant’s denial upon confrontation, the victim’s account was clear enough to spur further actions.

After the incident, AAA, while receiving a bath from her mother, cried out in pain when her vagina was washed, indicating further evidence of injury.
On May 8, 2006, following the incident, AAA underwent a physical/medical examination which revealed a slight hymenal abrasion on her vulva.
Her parents filed a report with the Barangay Chairman and subsequently, her mother filed a criminal complaint with the Prosecutor’s Office of Guiuan, Eastern Samar.
An Information was filed on August 2, 2006 charging Victor Padit with rape under provisions originally cited as Article 335 of the Revised Penal Code (RPC).

During pre-trial, both prosecution and defense stipulated certain facts: AAA's age (4 years), the identity of the accused, and the neighborly relationship among the parties.
On March 3, 2008, the Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt, sentencing him to reclusion perpetua and awarding damages to the victim.
The Court of Appeals (CA) in its Decision dated July 19, 2011, affirmed with modification the RTC’s ruling by adding exemplary damages to the award.
Accused-appellant later filed an appeal with the Supreme Court, challenging the prosecution’s proof and certain inconsistencies in witness testimonies.

Whether the prosecution was able to prove beyond reasonable doubt that accused-appellant committed rape/statutory rape against AAA.
Whether the victim’s testimony, given her tender age, can be accorded full credibility in establishing the elements of the crime.

The issue of mis-specification of the applicable law (charging under Article 335 of the RPC even though RA 8353 had reclassified rape as provided under Articles 266-A to 266-D).
Whether such an error in specifying the legal provision vitiates the Information or the conviction.

The reliability of AAA’s testimony as a minor and the inherent challenges in assessing her capacity to perceive, recall, and recount the events accurately.
The admissibility and supportive role of the mother’s testimony, given the concerns regarding hearsay evidence, in corroborating the victim’s account.