Facts:

• Rodolfo Pateao y Dayapdapan was accused of five counts of rape against his 14-year-old daughter, referred to as AAA.
• The incidents occurred around March 25, 2002, in Negros Oriental, Philippines.
• The Regional Trial Court (RTC) of Bais City, Branch 45, found Pateao guilty beyond reasonable doubt.
• Charges were filed under Criminal Case Nos. F-03-12-A, F-03-13-A, F-03-14-A, F-03-15-A, and F-03-16-A.
• Pateao pleaded not guilty during the arraignment.
• The prosecution presented AAA's testimony, detailing the assaults initiated by threats from her father.
• The abuse lasted for four consecutive nights, after which AAA confided in her teacher.
• Medical examinations supported AAA's claims, revealing physical evidence of sexual assault.
• Pateao denied the allegations, claiming AAA sought revenge for a reprimand during a beauty contest.
• The RTC sentenced him to reclusion perpetua for each count of rape and ordered damages to be paid to AAA.
• The Court of Appeals (CA) affirmed the RTC's decision on May 23, 2013, with modifications to the damages.

Issue:

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Ruling:

• The Supreme Court upheld the credibility of AAA's testimony, affirming Pateao's conviction for five counts of rape.
• The Court found that the prosecution sufficiently proved AAA's age through official records.
• The Court modified the damages ...(Unlock)

Ratio:

• The Supreme Court emphasized the significance of the victim's testimony in rape cases, noting the consistency of AAA's account.
• The Court referenced prior jurisprudence, stating that a victim's behavior in traumatic situations may not follow a predictable pattern.
• AAA's delayed reporting was deemed understandable due to her age and the psychological manipulation by her father...continue reading