GR 214880; (September, 2017) (Digest)
G.R. No. 214880 September 6, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. AMANTE PADLAN y LEONES, Accused-Appellant
FACTS
The accused-appellant, Amante Padlan, was charged with two counts of rape and one count of acts of lasciviousness against the minor “AAA,” who was nine years old at the time. The incidents allegedly occurred in Meycauayan, Bulacan, on August 7, 2005, September 27, 2005, and September 28, 2005. The prosecution’s version, as testified by AAA, detailed that Padlan, who was living with AAA’s family, sexually assaulted her on the first two dates, inserting his penis and finger into her vagina, and committed acts of lasciviousness by touching her vagina on the third date. AAA reported the assaults to her mother after complaining of pain, leading to Padlan’s arrest. The defense presented an alibi, claiming Padlan was in Nueva Ecija during the first alleged incident and denied all charges.
ISSUE
The core issue was whether the prosecution successfully proved Padlan’s guilt for the crimes charged beyond reasonable doubt, particularly in light of his defense of denial and alibi.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s candid, consistent, and straightforward narration of the traumatic events, given her young age, carried great weight and was deemed credible. The Court found no ill motive for AAA to falsely accuse Padlan. His defense of alibi was rejected as inherently weak and unsubstantiated by clear and convincing evidence; it could not prevail over the positive identification by the victim. Regarding the charges, the Court clarified the applicable laws. For the two rape incidents under Article 266-A of the Revised Penal Code (RPC) in relation to Republic Act (RA) 7610, the penalty was correctly imposed. However, for the acts of lasciviousness on September 28, 2005, the Court modified the legal basis. Since the information alleged “force and intimidation,” the crime was properly classified under Article 336 of the RPC, not Section 5(b) of RA 7610. Nevertheless, applying the Indeterminate Sentence Law, the penalty was within the range prescribed for the offense. The Court affirmed the awards of civil indemnity, moral damages, and exemplary damages, with legal interest, to the victim.