People v. Cadano
REITERATIONFacts
The Antecedents: Three Informations were filed charging Guillermo B. Cadano, Jr. (Cadano) with statutory rape against AAA, the daughter of his common-law spouse. The first two incidents occurred on December 26 and 27, 1996, when AAA was 8 years and 5 months old. The third incident occurred in June 2000, when AAA was 11 years and 11 months old. Cadano denied the allegations, claiming BBB, AAA's mother, filed the charges due to family problems. Procedural History: The Regional Trial Court (RTC) of Pasig City convicted Cadano of three counts of statutory rape, sentencing him to reclusion perpetua for each count and awarding damages. The Court of Appeals (CA) affirmed the RTC's decision in toto. Cadano appealed to the Supreme Court. The Petition: Cadano assailed his conviction by the CA, arguing that the evidence presented did not prove his guilt beyond reasonable doubt.
Issue(s)
Whether the guilt of accused-appellant Guillermo B. Cadano, Jr. for three (3) counts of statutory rape was proven beyond reasonable doubt. Whether the penalties and damages awarded by the lower courts were proper.
Ruling
The Supreme Court affirmed the conviction of Guillermo B. Cadano, Jr. for three (3) counts of statutory rape with modifications to the awarded damages. The penalties were affirmed, but the amounts for civil indemnity, moral damages, and exemplary damages were adjusted based on the applicable laws for each incident.
Ratio Decidendi
On the guilt of accused-appellant Guillermo B. Cadano, Jr. for three (3) counts of statutory rape: The Court held that the elements of statutory rape were sufficiently proven. The prosecution established AAA's age, proving she was below 12 years old at the time of the incidents through her Certificate of Live Birth. The identity of Cadano as the perpetrator was confirmed by AAA's positive, categorical, and spontaneous testimony, which was corroborated by the medico-legal report. The Court emphasized that for statutory rape, proof of force, intimidation, or consent is unnecessary because the law conclusively presumes the absence of free consent when the victim is below 12 years of age, as such a victim is presumed incapable of giving intelligent consent. The testimonies of child-victims are given full weight and credit due to their vulnerability and the shame they endure, and their youth and immaturity are generally badges of truth and sincerity. The Court found no reason to overturn the RTC's assessment of AAA's credibility, which was affirmed by the CA, as there was no evidence of arbitrariness or oversight. On the penalties and damages awarded: The Court affirmed the penalty of reclusion perpetua for each count of statutory rape. It clarified that the first two incidents, occurring before RA 8353, were governed by Article 335 of the RPC, while the third incident, occurring after RA 8353, was governed by Articles 266-A and 266-B of the RPC. The Court noted that RA 8353 introduced qualifying circumstances, such as the offender being a common-law spouse of the parent of the victim, which could elevate the penalty to death, but this was not applicable to the first two incidents due to the law's effectivity. However, due to the abolition of the death penalty by RA 9346, the penalty for the third incident remained reclusion perpetua without eligibility for parole. The Court found that the RTC and CA erred in the awarded damages for all three counts. For the first two counts (under old RPC), the proper awards were ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, and ₱30,000.00 as exemplary damages per count. For the third count (under amended RPC), the proper awards were ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱30,000.00 as exemplary damages, considering the aggravating circumstances that would have warranted the death penalty. Legal interest was ordered to be paid from the date of filing of the information until fully paid.
Main Doctrine
The elements of statutory rape are: (a) the age of the complainant; (b) the identity of the accused; and (c) the sexual intercourse between the accused and the complainant. Proof of force, intimidation, or consent is unnecessary when the victim is below 12 years of age, as the law presumes the absence of free consent.