Case Summary (G.R. No. 202978)
Antecedents of the Case
The events transpired on May 5, 2006, when AAA was called by the accused, who was her neighbor and uncle of her mother, into his home. Initially, AAA was outside purchasing bread. The accused subsequently committed acts of sexual violence against her, which included covering her mouth to prevent her from screaming. After the incident, AAA confided in her mother about the assault, leading to a complaint being lodged with local authorities. A subsequent medical examination revealed slight hymenal abrasion, consistent with sexual violence.
Charges and Proceedings
On August 2, 2006, Victor Padit was formally charged with the crime of rape under Article 335 of the Revised Penal Code. The accused denied the allegations, asserting an alibi supported by his wife. During pre-trial, essential facts regarding the age of the victim, the relationship between the accused and victim, and the circumstances surrounding the incident were stipulated by both the prosecution and the defense.
Regional Trial Court Decision
On March 3, 2008, the RTC found Padit guilty of rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and moral damages to the victim. The decision emphasized the credibility of AAA's testimony, which was corroborated by medical findings.
Court of Appeals Ruling
After Padit appealed to the CA, the court affirmed the RTC's decision on July 19, 2011, with modifications, including an additional award for exemplary damages. The CA underscored that the prosecution successfully established the elements of rape, reinforcing the credibility of the victim’s testimony.
Appeal to the Supreme Court
Padit sought further appeal to the Supreme Court, which deliberated on whether the prosecution had proven his guilt beyond reasonable doubt. The core issue involved the sufficiency of the evidence presented, particularly the credibility of the victim's account and medical corroboration.
Legal Analysis and Findings
The Supreme Court identified that while the Information cited the incorrect provision of law due to subsequent amendments (RA 8353 reclassifying rape), the facts alleged sustained the charges under the revised definitions. The Court emphasized that minor discrepancies in testimony do not undermine the victim’s credibility, especially given her age and the accompanying trauma of the incident.
Conclusion on Guilt
The Supreme Court ultimately affirmed the conviction, noting that the acts described by AAA fulfilled the definition of statutory rape, given her age at the time of the incident. It upheld the penalties imposed by both the RTC and CA, speci
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Case Overview
- The case involves an ordinary appeal filed by accused-appellant Victor P. Padit against the Decision of the Court of Appeals dated July 19, 2011.
- The Court of Appeals affirmed with modification the Decision of the Regional Trial Court (RTC) of Guiuan, Eastern Samar, which found Padit guilty of rape.
- The case centers on the events of May 5, 2006, involving the victim, a four-year-old girl referred to as AAA.
Factual Background
- On May 5, 2006, AAA was playing inside her home while her mother attended to her younger brother.
- AAA left the house to buy bread but was called by Padit, her neighbor and uncle to her mother, whom she referred to as "Lolo Victor."
- Inside Padit's home, AAA was taken upstairs, made to lie down, and Padit removed both their pants.
- Padit rubbed his penis against AAA's vagina, causing her pain, while threatening her with a knife to keep quiet about the incident.
- AAA's mother noticed her absence, searched for her, and when she found her, AAA disclosed the molestation.
- Following this, AAA's mother confronted Padit, who denied the allegations.
Medical Examination and Legal Proceedings
- After reporting the incident, AAA underwent a medical examination on May 8, 2006, which revealed slight hymenal abrasion.
- A criminal complaint was filed against Padit, and he was charged with rape under the Revised Penal Code.
- During the trial, the defense was based on Padit's claim that his wife was with him at the time of the alleged crime, corroborated by her testimony.
Trial Court Ruling
- The RTC found Padit guilty of consummated rape, sentencing him to reclusion perpetua and ordering him to pay c