Facts:

The case involves Rodolfo Pateao y Dayapdapan, who was accused of committing five counts of rape against his 14-year-old daughter, referred to as AAA. The incidents occurred on or about March 25, 2002, in Negros Oriental, Philippines. The Regional Trial Court (RTC) of Bais City, Branch 45, found Pateao guilty beyond reasonable doubt of these charges, which 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. During the arraignment, Pateao pleaded not guilty. The prosecution presented evidence, including AAA's testimony, which detailed the assaults that began when she was awakened by her father, who threatened her with a scythe and forced her to submit to his advances. This abuse continued for four consecutive nights. After enduring this trauma, AAA sought refuge with her teacher, where she disclosed the incidents. Medical examinations corroborated her claims, revealing physical evidence of sexual assault. Pateao denied the allegat...

Facts:

Background of the Case

• The case involves accused-appellant Rodolfo Pateao y Dayapdapan, who was charged with five counts of rape against his 14-year-old daughter, AAA.
• The incidents allegedly occurred on or about March 25, 2002, in Negros Oriental, Philippines.

Stipulations During Pre-Trial

• Accused-appellant admitted his identity as the accused in the five cases.
• He acknowledged that he is the father of the victim, AAA.
• He confirmed that he resided in Negros Oriental.
• The victim, AAA, admitted to participating in a beauty pageant involving monetary contributions.

Victim’s Testimony

• AAA testified that she was left in the care of her aunt, BBB, at the age of four and only started living with her father in 2000.
• On March 25, 2002, at around 10:00 p.m., AAA was awakened by her father, who removed her clothes and threatened her with a scythe.
• Accused-appellant proceeded to rape her, repeating the act for four consecutive nights.
• Unable to endure the abuse, AAA left the house and confided in her teacher about the incidents.

Medical Examination

• AAA underwent a medical examination on April 5, 2002, which revealed:
  • Contusion on the upper border of the iliac region.
  • Old hymenal tears at the 3 and 9 o'clock positions.
  • No discharges, and the vagina admitted two fingers with ease.

Evidence of Minority

• A pastor from the United Church of Christ of the Philippines (UCCP) testified that AAA was born on September 10, 1987, and was baptized on June 5, 1988.
• The UCCP Membership Record Book listed accused-appellant as AAA’s father.

Defense’s Claims

• Accused-appellant denied the allegations, claiming that AAA fabricated the charges out of revenge for being scolded and pinched during a beauty pageant.
• His nephew, Rene, and Rene’s sister, Arly, testified that AAA was not living with accused-appellant during the alleged incidents and speculated that AAA harbored a grudge against him.

Issue:

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Ruling:

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Ratio:

1. Credibility of the Victim’s Testimony: The Court held that AAA’s testimony was credible and consistent. The uniformity of her account of the rape incidents did not diminish her credibility, as it is common for perpetrators to repeat successful methods of abuse.
2. Qualifying Circumstances: The twin circumstances of minority and relationship were proven through the UCCP Membership Record Book and accused-appellant’s admission. These circumstances qualified the crime and warranted the imposition of the maximum penalty.
3. Defense of Fabrication: The Court rejected accused-appellant’s claim that AAA fabricated the charges out of revenge. It emphasized that no woman, especially a young girl, would falsely accuse someone of such a grave crime.
4. Penalties and Damages: The Court imposed the penalty of reclusion perpetua without eligibility for parole for each count of rape, in lieu of the death penalty, pursuant to Republic Act No. 9346. The damages were increased to reflect the gravity of the crime and to provide adequate compensation to the victim.

Conclusion:

• Accused-appellant Rodolfo Pateao y Dayapdapan was found guilty of five counts of rape qualified by minority and relationship. He was sentenced to reclusion perpetua without parole and ordered to pay increased damages to the victim, AAA.