Case Summary (G.R. No. 209040)

Overview of the Case

• The case involves Rodolfo Pate o y Dayapdapan, who was found guilty of five counts of rape against his 14-year-old daughter, AAA.
• The Regional Trial Court (RTC) of Bais City initially convicted him, and the Court of Appeals (CA) affirmed this decision.
• The charges were based on incidents occurring on March 25, 2002, and the subsequent nights, where AAA was subjected to sexual assault by her father.

Factual Background

• The accused-appellant admitted his identity and relationship to the victim during pre-trial.
• AAA had been living with her father since 2000, after being cared for by her aunt for several years.
• The assaults began on the night of March 25, 2002, when AAA was threatened with a scythe and forced to submit to her father's sexual advances.
• AAA reported the incidents to her teacher after escaping to her home for safety.

Medical Examination and Testimony

• A medical examination conducted on April 5, 2002, revealed physical evidence consistent with sexual assault, including an old hymenal tear.
• Testimonies from a pastor confirmed AAA's birth date and her relationship with the accused, establishing her age at the time of the incidents.
• The accused denied the allegations, claiming AAA was motivated by revenge due to a reprimand during a beauty contest.

Trial Court's Decision

• On April 27, 2007, the RTC convicted Rodolfo Pate o y Dayapdapan of five counts of rape, sentencing him to reclusion perpetua and ordering him to pay damages to AAA.
• The RTC's decision was based on the credibility of AAA's testimony and the corroborating evidence presented.

Court of Appeals' Ruling

• The CA affirmed the RTC's decision on May 23, 2013, with modifications regarding the amount of damages awarded to AAA.
• The CA emphasized the gravity of the offenses and the need for appropriate compensation for the victim.

Accused-Appellant's Arguments on Appeal

• The accused-appellant contended that AAA's testimony was implausible and lacked credibility.
• He argued that the prosecution failed to prove AAA's age and that her accusations were motivated by personal grievances.
• The appeal was ultimately deemed without merit by the higher court.

Court's Analysis of Credibility

• The court upheld AAA's credibility, noting that her delayed reporting was understandable given her age and the circumstances of the abuse.
• The court referenced previous rulings to support the notion that a victim's consistent testimony, even if it describes repeated assaults, does not diminish credibility.

Legal Findings on Minority and Relationship

• The court confirmed the presence of qualifying circumstances of minority and relationship, which were established through official records.
• The relationship between the accused and AAA was acknowledged, reinforcing the severity of the crimes committed.

Penalty and Damages

• The court ruled that the appropriate penalty for the crimes, given the q...continue reading