G.R. No. 182917 ; June 8, 2011
People of the Philippines, Plaintiff-Appellee, vs. Benjamin Padilla y Untalan, Accused-Appellant.

FACTS

Accused-appellant Benjamin Padilla y Untalan was charged with three counts of rape under three separate Informations dated March 12, 2001. The charges alleged that he, being the father of the private complainant AAA, a minor, had carnal knowledge of her by means of force and intimidation on the following dates: sometime in November 1999 (Criminal Case No. U-11275), on or about January 13, 2001 (Criminal Case No. U-11273), and at about dawn of January 14, 2001 (Criminal Case No. U-11274). During pre-trial, the parties stipulated on: (1) the identity of the accused; (2) the identity of AAA; (3) that the accused is the father of AAA; and (4) that AAA is a minor, having been born on February 28, 1989.
The prosecution presented AAA’s testimony detailing the incidents. For the November 1999 incident, she testified that at around 7:00 a.m., while changing clothes on the second floor of their house, the accused-appellant entered, held her arm, threatened her with a bolo, pushed her to the floor, removed her clothing, spread her legs, and had sexual intercourse with her. For the January 13, 2001 incident, she stated that in the evening, while changing clothes upstairs, the accused-appellant again threatened her with a bolo, pushed her, removed her clothing, and raped her. For the January 14, 2001 incident, she testified that at dawn while sleeping on the ground floor, the accused-appellant woke her, whispered threats, removed her clothing, and raped her. She reported the incidents to her aunt FFF and grandmother GGG on January 14, 2001, leading to a police report and medical examination.
The prosecution also presented: SPO2 Patricio Badua, Jr., who received the report and recorded it in the police blotter; FFF, who corroborated AAA’s report; GGG, who confirmed AAA’s parentage and the report; and Dr. Noemie Taganas, who medically examined AAA on January 14, 2001, and found swelling on her nipples and genitalia, and old healed hymenal lacerations at 12, 3, 6, and 9 o’clock positions, leading to a diagnosis of “Physical Virginity, Lost.”
The defense presented the testimony of CCC, AAA’s older brother, who stated he had no knowledge of the alleged incidents and that the family usually slept side by side on the lower floor. The accused-appellant testified, denying the allegations and presenting an alibi, stating he was working as a porter or fruit seller during the alleged times.
The Regional Trial Court convicted the accused-appellant of three counts of rape. The Court of Appeals affirmed the conviction with modification. The accused-appellant appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for three counts of rape.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATION as to the awards of damages. The Court found the appeal devoid of merit.
The Court held that the prosecution successfully proved the guilt of the accused-appellant beyond reasonable doubt. The credible, candid, and consistent testimony of AAA, a minor, on the specific details of the rape incidents was given full weight. The Court emphasized that when the victim’s testimony is credible, it is sufficient to support a conviction for rape. The medical findings of old healed hymenal lacerations corroborated AAA’s claim of prior sexual abuse. The defense of denial and alibi, which are inherently weak defenses, could not prevail over the positive identification and categorical testimony of the victim. The relationship of father and daughter, which was stipulated, qualified the rape and warranted the imposition of the death penalty under the law at the time of commission. However, due to the passage of Republic Act No. 9346 prohibiting the death penalty, the penalty was reduced to reclusion perpetua without eligibility for parole. The Court awarded civil indemnity, moral damages, and exemplary damages for each count of rape.