G.R. No. 231306 June 17, 2019
People of the Philippines, Plaintiff-Appellee vs. Pierre Adajar y Tison @ Sir Paul, Accused-Appellant

FACTS

Accused-appellant Pierre Adajar, the dance instructor of the 10-year-old victim AAA, was charged with four counts of rape under Article 266-A of the Revised Penal Code. The prosecution established that Adajar, having endeared himself to AAA’s family and staying in their residence, committed various sexual assaults against AAA between January and February 2010. These acts included kissing her, inserting his finger into her vagina, forcing her to hold his penis, and, on two separate occasions, having carnal knowledge of her. The victim’s mother discovered inappropriate text messages from Adajar to AAA, prompting her confrontation, which led to AAA’s disclosure of the abuses.
The Regional Trial Court convicted Adajar of four counts of rape. On appeal, the Court of Appeals affirmed the conviction but modified the penalties, imposing reclusion perpetua without eligibility for parole for the two counts of qualified rape (sexual intercourse) and indeterminate prison terms for the two counts of acts of sexual assault. Adajar appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the victim’s testimony.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant Pierre Adajar’s conviction for four counts of rape.

RULING

The Supreme Court denied the appeal and affirmed the CA decision with modifications on damages. The Court upheld the conviction, emphasizing that the credibility of the young victim’s clear, candid, and consistent testimony, which withstood rigorous cross-examination, deserves full weight. The Court found no ill motive for AAA to falsely accuse her instructor, whom she once trusted. The defense of denial and alibi, uncorroborated and inherently weak, could not prevail over the positive identification by the victim.
Regarding the penalties, the Court affirmed that the two instances of sexual intercourse constituted qualified rape under Article 266-B, punishable by reclusion perpetua to death. Applying prevailing jurisprudence and considering the absence of any aggravating circumstance, the proper penalty is reclusion perpetua without eligibility for parole. For the two counts of sexual assault (acts of lasciviousness under Article 266-A(2)), the Court affirmed the indeterminate prison sentences. The Court also awarded civil indemnity, moral damages, and exemplary damages for each count, with interest, following current policy. The totality of evidence established Adajar’s guilt beyond reasonable doubt for all charges.