GR 209040; (December, 2015) (Digest)
G.R. No. 209040, December 09, 2015
People of the Philippines, Plaintiff-Appellee, vs. Rodolfo Pateño y Dayapdapan, Accused-Appellant.
FACTS
Accused-appellant Rodolfo Pateño was charged with five counts of rape against his 14-year-old daughter, AAA. The Informations alleged that on five successive nights starting March 25, 2002, he, by force and intimidation with a scythe, had carnal knowledge of AAA in their home. AAA testified to the repeated assaults, after which she fled and reported the incidents to her teacher. Medical examination revealed an old hymenal tear. The defense presented an alibi, with the appellant’s nephew and niece testifying that AAA was not living with him during the alleged period. They also claimed AAA fabricated the charges due to a grudge, as the appellant often scolded her and had pinched her during a beauty pageant.
ISSUE
The core issues were: (1) whether AAA’s testimony was credible despite its uniformity across the five incidents; (2) whether the prosecution sufficiently proved AAA’s minority; and (3) whether the defense of alibi and alleged motive to fabricate could prevail.
RULING
The Supreme Court affirmed the conviction. On credibility, the Court held that the uniformity of AAA’s testimony on the manner of rape does not render it improbable; rapists often follow a set pattern, especially in sequential assaults within a familial context. AAA’s straightforward and consistent narration, coupled with her immediate disclosure to a teacher, bolstered her credibility. The alleged motive of resentment from being scolded or pinched is trivial and insufficient to make a daughter falsely accuse her father of a grave crime.
Regarding proof of age, the Court ruled it was established beyond reasonable doubt. The defense itself stipulated during pre-trial that the appellant is AAA’s father. Furthermore, the pastor’s testimony and the Membership Record Book, an official record made in the course of duty, constituted prima facie evidence of AAA’s birthdate under Rule 130, Section 44 of the Rules of Court. The defense failed to rebut this evidence. The qualifying circumstances of minority and relationship were thus proven, warranting the imposition of reclusion perpetua without eligibility for parole for each count. The awards for civil indemnity, moral damages, and exemplary damages were increased to ₱100,000.00 each per count, with legal interest.