GR 137648; (March, 2001) (Digest)
G.R. No. 137648 ; March 30, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IRENEO PADILLA y VILLASEÑOR alias “Iring”, defendant-appellant.
FACTS
The accused-appellant, Ireneo Padilla, was charged with the rape of his ten-year-old daughter, Eula Padilla, on November 3, 1995, in Taguig, Metro Manila. The prosecution presented Eula’s testimony that her father tied her hands and feet, covered her mouth, and forcibly had sexual intercourse with her while she was sleeping. Her mother, Esmeralda, corroborated the account, stating she discovered bloodstains on Eula’s shorts, leading to the child’s disclosure. The medico-legal report confirmed findings compatible with recent loss of virginity. The accused initially pleaded guilty but changed his plea to not guilty upon learning the death penalty was mandatory. He denied the accusation, claiming it was fabricated by his in-laws and that he was elsewhere during the alleged incident.
ISSUE
The core issues were whether the prosecution proved the accused’s guilt beyond reasonable doubt and whether the qualifying circumstance of relationship, which would warrant the death penalty, was sufficiently established.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that the testimony of the young victim, given in a categorical, straightforward, and consistent manner, was credible and sufficient to establish the fact of rape. The Court emphasized that in rape cases, the victim’s testimony, if credible, is enough to sustain a conviction. The medical findings, which showed a freshly lacerated hymen, strongly corroborated her account of a recent sexual assault. The defense of denial and alibi was deemed weak and unsubstantiated, especially against the positive identification by the victim.
Regarding the penalty, the Court ruled that the qualifying circumstance of relationship—that the offender is the parent of the victim—was duly proven. The Information explicitly alleged this relationship, and it was established during trial through the testimonies of both the victim and her mother, who confirmed the accused was Eula’s father. This relationship, under Article 335 of the Revised Penal Code as amended by R.A. 7659, qualified the crime for the imposition of the death penalty. The Court modified the award of damages, increasing the civil indemnity to P75,000.00 and awarding P50,000.00 as moral damages.