G.R. No. 202978 February 1, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. VICTOR P. PADIT, Accused-Appellant.

FACTS

On May 5, 2006, four-year-old AAA was sent by her mother to buy bread. Their neighbor, accused-appellant Victor Padit, whom AAA called “Lolo Victor,” called her into his house. He brought her upstairs, made her lie down, and removed her short pants. He then removed his own pants and proceeded to rub his penis against AAA’s vagina. AAA felt pain but was prevented from shouting as Padit covered her mouth. He later threatened her with a knife if she told anyone. When AAA’s mother went looking for her, Padit initially claimed AAA was inside watching him weave baskets before bringing her out. Upon returning home, AAA recounted the assault to her mother, who later observed the child wincing in pain while bathing her. A medical examination revealed a slight hymenal abrasion.
Padit denied the accusation, asserting his wife was with him at the time, a claim corroborated by his wife. The Regional Trial Court (RTC) found him guilty of rape under Article 335 of the Revised Penal Code, as amended, and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction but modified the damages by adding an award for exemplary damages.

ISSUE

Whether the CA correctly affirmed the RTC’s finding that accused-appellant’s guilt for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the conviction was proper. The Supreme Court affirmed the decisions of the lower courts. The prosecution successfully established all elements of rape through AAA’s credible and categorical testimony, which was consistent with human experience and duly corroborated by medical findings. The Court emphasized that the testimony of a child-victim, given in a straightforward and candid manner, is accorded full weight and credit. The defense of denial and alibi presented by Padit and his wife cannot prevail over the positive identification and clear narration of the victim. Denial is inherently weak and, unless substantiated by clear and convincing evidence, deserves no merit. The physical evidence, though slight, supported AAA’s account of sexual contact. The imposable penalty for statutory rape, where the victim is under twelve years of age, is reclusion perpetua, as the death penalty was prohibited at the time of the commission of the crime. The awards of civil indemnity, moral damages, and exemplary damages were sustained in accordance with prevailing jurisprudence.