G.R. No. 142899; March 31, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. CESAR GLORIOSO LAGRONIO PADILLA, a.k.a. Erick Padilla, appellant.

FACTS

The appellant, Cesar Padilla, was the common-law husband of Elisa Mallorca and lived with her and her eight-year-old daughter, Laiza Mallorca-Salvador. On April 18, 1999, in Romblon, Romblon, Laiza was left alone with the appellant. According to the prosecution, the appellant, armed with a balisong, ordered Laiza inside their house, forced her to lie down, removed her underwear, and had carnal knowledge of her against her will. Laiza testified to feeling pain, shouting for help, and subsequently bleeding. She reported the incident to her mother, leading to a medical examination and the filing of a rape complaint. The medico-legal certificate confirmed a healed hymenal laceration consistent with penile penetration.
The appellant presented a different version, claiming that Laiza was accidentally injured when she climbed onto him, lost her balance, and was caught by his hand, which hit her vagina. He alleged the complaint was motivated by his common-law wife’s jealousy after she discovered he was courting another woman. The defense also presented the examining physician, who testified that Laiza consulted him for a rape complaint, not for an infection from an accidental injury.

ISSUE

Whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, a child of tender age, to be credible, straightforward, and consistent. It held that when the victim’s testimony is credible, it is sufficient to sustain a conviction for rape. The Court emphasized that the testimony of a young rape victim is given full weight and credit, as her innocence renders her incapable of fabricating a charge of such gravity. The medical findings, while indicating a healed laceration, corroborated her account of prior sexual abuse and were consistent with her testimony of pain and bleeding on the specific date in question.
The Court rejected the appellant’s defense of accidental injury as inherently improbable and contrived. His claim of ill-motive on the part of the complainant and her mother was deemed insufficient to overturn the positive identification and credible narrative of the victim. The qualifying circumstance of the victim being under eighteen years of age and the offender being the common-law spouse of the victim’s parent was duly proven, warranting the imposition of the death penalty under the law at the time. However, following the ruling in People vs. Ereno, the Court modified the award of damages, increasing the civil indemnity and awarding moral and exemplary damages. The death penalty was subsequently reduced to reclusion perpetua in line with the prevailing jurisprudence after the abolition of the death penalty.