GR 218570; (November, 2017) (Digest)
March 17, 2026GR 110289; (October, 1994) (Digest)
March 17, 2026G.R. No. 181202; December 5, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. EDGAR PADIGOS, Accused-Appellant.
FACTS
The accused-appellant, Edgar Padigos, was charged with rape and acts of lasciviousness against his six-year-old daughter, AAA, in relation to Republic Act No. 7610. The prosecution alleged that on August 26, 2002, Padigos, while alone with the victim, undressed her and had carnal knowledge, causing her pain. The following day, he made her hold his penis and touched her genitals. The victim reported the incidents to her mother and aunt, leading to a medical examination and a police report. The defense claimed the charges were fabricated by his estranged wife due to marital conflict, asserting that the child had not been in his custody since their separation.
ISSUE
The core issue was whether the prosecution successfully proved the guilt of the accused-appellant for the crimes of rape and acts of lasciviousness beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the child victim’s testimony was paramount. At six years old, AAA gave a clear, consistent, and candid account of the sexual assaults, which bore the hallmarks of truth. The Court ruled that the testimony of a child victim, especially when straightforward and unshaken by cross-examination, is accorded full weight and credit. The medical findings, though indicating a healed hymenal laceration, were consistent with her account and supported the fact of violation.
The defense of denial and frame-up was rejected for being weak and unsupported by clear and convincing evidence, especially when juxtaposed with the positive and credible identification by the victim. The qualifying circumstances of minority and relationship were duly proven, warranting the imposition of the proper penalties under R.A. 7610. The Court modified the damages, increasing exemplary damages to P30,000.00 and imposing legal interest on all monetary awards from the finality of judgment. The decision underscores the principle that the lone testimony of a credible child victim suffices for conviction if it meets the test of credibility.
