Title
People vs. Padlan y Leones
Case
G.R. No. 214880
Decision Date
Sep 6, 2017
Amante Padlan convicted of raping a 9-year-old minor, "AAA," on multiple occasions; alibi defense rejected; sentenced to reclusion perpetua and damages.
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Case Summary (G.R. No. 214880)

Case Background and Charges

  • Amante Padlan y Leones was charged with two counts of rape and one count of acts of lasciviousness against a nine-year-old girl, referred to as "AAA."
  • The charges were filed under Article 266-A of the Revised Penal Code (RPC) in relation to Republic Act No. 7610 (RA 7610).
  • The incidents occurred in Meycauayan, Bulacan, on August 7, 2005, September 27, 2005, and September 28, 2005.
  • The prosecution alleged that Padlan used force and intimidation to commit the crimes, which severely affected the emotional and psychological well-being of the victim.

Arraignment and Trial Proceedings

  • Padlan pleaded not guilty during his arraignment on October 24, 2005.
  • The prosecution presented testimonies from "AAA" and her mother, "BBB," while Padlan testified in his defense.
  • "AAA" detailed the incidents, describing how Padlan assaulted her and threatened her to prevent her from reporting the abuse.

Testimonies of the Victim and Witnesses

  • "AAA" testified that on August 7, 2005, Padlan woke her up, touched her inappropriately, and raped her.
  • On September 27, 2005, Padlan again assaulted "AAA" under the pretense of taking her to borrow money.
  • On September 28, 2005, "AAA" reported to her mother that she was in pain, leading to an examination that revealed signs of sexual abuse.
  • "BBB" confronted Padlan, who allegedly admitted to the rapes, prompting a police report.

Defense and Alibi

  • Padlan denied the charges, claiming he was elsewhere during the incidents.
  • He provided an alibi stating he was in Nueva Ecija buying vegetables and later resting at home.
  • The defense did not present corroborating evidence for Padlan's alibi, which was deemed weak against the victim's testimony.

Ruling of the Regional Trial Court

  • On November 10, 2011, the RTC found Padlan guilty of the charges based on the credible testimonies of "AAA" and "BBB."
  • The RTC sentenced Padlan to reclusion perpetua for the rape charges and imposed a lesser penalty for the acts of lasciviousness.

Ruling of the Court of Appeals

  • The Court of Appeals affirmed the RTC's decision on April 15, 2014, with modifications to the damages awarded to the victim.
  • The CA increased the civil indemnity and moral damages to P75,000.00 each and awarded P30,000.00 as exemplary damages for the rape cases.

Appeal to the Supreme Court

  • Padlan appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt and challenging the credibility of "AAA."
  • The Supreme Court reviewed the case and found no reason to overturn the lower courts' findings.

Supreme Court's Ruling on Guilt

  • The Supreme Court upheld the findings of the RTC and CA, confirming that the prosecution proved all elements of the crimes charged.
  • The Court emphasized that the age of the victim and the nature of the acts committed constituted statutory rape....continue reading

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