G.R. No. 250418, December 09, 2020
People of the Philippines, Plaintiff-Appellee, vs. Roger Padin y Tilar, Accused-Appellant.

FACTS

Accused-appellant Roger Padin y Tilar was charged with Rape under Article 266-A of the Revised Penal Code, as amended, in relation to Republic Act No. 7610. The Information alleged that on or about April 4, 2012, in Catanduanes, he, by means of force, threat, and intimidation, had carnal knowledge of AAA, a 12-year-old child, without her consent. Accused-appellant was the live-in partner of BBB, AAA’s mother.
The prosecution’s evidence established that on the evening of April 4, 2012, AAA was sleeping in a room with her siblings when she was awakened by the accused-appellant, who was half-naked. He removed her shorts and underwear, laid on top of her, inserted his finger into her vagina, and then inserted his penis, performing a “push-and-pull” movement. Out of fear, AAA cried but did not resist or shout. After the act, accused-appellant left. BBB later received an anonymous text message alerting her to the abuse, prompting her to confront AAA, who then disclosed the repeated sexual abuses. AAA was medically examined on April 9, 2012, by Dr. Monisita Genogaling-Lacorte, whose findings (abrasion on the labia minora, lacerated wound on the fourchette, and a ruptured hymen admitting two fingers) were suggestive of penetration by a firm object or penis.
In his defense, accused-appellant denied the charge, claiming he was at home with BBB and the children on the night in question after having been released from detention that morning. He alleged that BBB fabricated the case due to a prior argument. CCC, AAA’s younger brother, testified for the defense, claiming he never saw the abuse and pointed to another person as the perpetrator.
The Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt of Rape, sentencing him to reclusion perpetua without eligibility for parole and ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision.

ISSUE

Whether the Court of Appeals’ Decision affirming accused-appellant’s conviction for Rape is contrary to facts, law, and jurisprudence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction.
The Court held that all elements of simple rape under Article 266-A of the Revised Penal Code were present: (1) accused-appellant had carnal knowledge of AAA, and (2) the act was accomplished through force or intimidation. AAA’s clear, consistent, and straightforward testimony, corroborated by the medico-legal findings of penetration, sufficiently established carnal knowledge. Regarding force or intimidation, the Court ruled that where the offender is a person who holds moral ascendancy or influence over the victim, such as the common-law spouse of the victim’s mother, moral influence takes the place of violence or intimidation. Thus, the element of force or intimidation was satisfied.
The Court found AAA’s testimony credible and rejected the defenses of denial and alibi. It emphasized that the testimony of a young rape victim, when credible, is sufficient to sustain a conviction. The positive identification by AAA, who knew accused-appellant well as her mother’s partner, prevailed over his bare denial. The medical evidence fortified her account. The testimony of defense witness CCC was deemed unreliable, as it was refuted by accused-appellant’s own admission of being at home on the night of the incident.
Regarding the penalty, the crime was qualified as statutory rape under Article 266-A(1)(d) because the victim was under 12 years old at the time of the commission (born September 20, 1999; raped April 4, 2012). The prescribed penalty under Article 266-B is reclusion perpetua. The Court affirmed the imposition of reclusion perpetua without eligibility for parole, pursuant to Section 3 of Republic Act No. 9346. The awards of damages were modified in line with prevailing jurisprudence. Accused-appellant was ordered to pay AAA Php75,000.00 as civil indemnity, Php75,000.00 as moral damages, and Php75,000.00 as exemplary damages, all with legal interest at 6% per annum from the finality of judgment until fully paid.