Case Digest (G.R. No. 214880)
Facts:
The case involves Amante Padlan y Leones, also known as Butog, who was accused of committing two counts of rape and one count of acts of lasciviousness against a nine-year-old girl referred to as "AAA." The incidents occurred in Meycauayan, Bulacan, Philippines, on August 7, 2005, September 27, 2005, and September 28, 2005. The prosecution filed three Informations against Padlan, charging him under Article 266-A of the Revised Penal Code (RPC) in relation to Republic Act No. 7610 (RA 7610) for the rapes, and under Article 336 of the RPC for acts of lasciviousness.
During the trial, "AAA" testified that on August 7, 2005, while she was sleeping, Padlan woke her up, touched her vagina, and subsequently raped her. He threatened her to prevent her from reporting the incident. The second incident occurred on September 27, 2005, when Padlan again raped "AAA" after luring her under the pretense of needing to borrow money. The third incident of lasciv...
Case Digest (G.R. No. 214880)
Facts:
1. Charges Against the Accused:
Amante Padlan y Leones (Padlan) was charged with two counts of rape under Article 266-A of the Revised Penal Code (RPC) in relation to Republic Act No. 7610 (RA 7610) and one count of acts of lasciviousness under Article 336 of the RPC in relation to RA 7610. The crimes were allegedly committed against "AAA," a 9-year-old minor, on August 7, 2005, September 27, 2005, and September 28, 2005, in Meycauayan, Bulacan.
2. Testimonies of the Prosecution:
- Incident on August 7, 2005: "AAA" testified that Padlan woke her up, touched her vagina, removed her clothes, and inserted his penis into her vagina despite her pain and protests. He later inserted his finger into her vagina.
- Incident on September 27, 2005: Padlan lured "AAA" to an aratiles tree, removed her clothes, and raped her.
- Incident on September 28, 2005: While "AAA" was sleeping, Padlan touched and rubbed her vagina, prompting her to run to her mother.
3. Medical Examination and Report:
"AAA" complained of pain in her vagina, and her mother noticed swelling and pus. Padlan admitted to raping "AAA" twice after being confronted by "BBB."
4. Defense of the Accused:
Padlan denied the charges and presented an alibi, claiming he was in Nueva Ecija on August 7, 2005, and at the market or resting at home on September 27-28, 2005. He argued that the prosecution failed to prove his guilt beyond reasonable doubt.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Elements of Statutory Rape: Under Article 266-A of the RPC, rape is committed when the victim is under 12 years old, and carnal knowledge is proven. "AAA" was 9 years old at the time of the incidents, and her testimony, supported by medical evidence, established the commission of rape.
- Acts of Lasciviousness Under RA 7610: The Court found that the elements of lascivious conduct under Section 5(b) of RA 7610 were sufficiently proven. The act of touching "AAA's" vagina constituted sexual abuse, and the penalty was modified to reclusion temporal.
- Credibility of the Victim: The Court upheld the credibility of "AAA's" testimony, noting that it was given in a clear and candid manner, consistent with the behavior of a child victim.
- Weakness of Alibi: Padlan's alibi was uncorroborated and failed to establish physical impossibility. His presence near the scene of the crime further weakened his defense.
- Awards of Damages: The Court increased the awards of civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence to provide full compensation for the victim's suffering.