People v. Pateño
REITERATIONFacts
The Antecedents: The accused-appellant, Rodolfo Pateño y Dayapdapan, was charged with five counts of rape against his 14-year-old daughter, AAA. The Informations alleged that on or about March 25, 2002, at around 10:00 p.m., the accused, by force and threat of a scythe, inserted his penis into the vagina of his daughter and had carnal knowledge of her against her will. This act was allegedly repeated for four succeeding nights. The victim, AAA, left the house and confided in her teacher. A medical examination revealed an old hymenal tear and the ability to admit two fingers with ease. A baptismal and membership record from the UCCP confirmed AAA's birthdate and that the accused was her father. Procedural History: The Regional Trial Court (RTC) of Bais City, Branch 45, found the accused-appellant guilty beyond reasonable doubt of five counts of rape and sentenced him to five counts of reclusion perpetua, ordering him to pay damages. The Court of Appeals (CA) affirmed the RTC decision with modifications as to damages. The accused-appellant filed the instant appeal. The Petition: The accused-appellant argued that AAA's testimony was incredible, that AAA had a motive to falsely accuse him due to his reprimands, and that the prosecution failed to prove AAA's age at the time of the commission of the crime.
Issue(s)
Whether the testimony of the victim regarding the repeated nature of the rape incidents is credible. Whether the accused-appellant's claim of revenge as a motive for the false accusation is tenable. Whether the prosecution sufficiently proved the age of the victim at the time of the alleged commission of the crime. Whether the twin qualifying circumstances of minority and relationship were sufficiently established. Whether the penalty and damages awarded were proper.
Ruling
The Supreme Court denied the appeal, finding the accused-appellant guilty beyond reasonable doubt for each of the five counts of rape. The Court affirmed the penalty of reclusion perpetua without eligibility for parole for each count, and modified the awards for civil indemnity, moral damages, and exemplary damages.
Ratio Decidendi
On the credibility of the victim's testimony regarding repeated incidents: The Court held that the victim's uniform testimony regarding the manner by which she was raped does not diminish her credibility. Citing People v. Solomon, the Court explained that men are creatures of habit and tend to repeat successful actions. The Court also noted that the victim's delay in reporting and her suffering through four more incidents before escaping were plausible explanations for her conduct, especially given her youth and the perceived parental authority of the accused. Under emotional stress, the human mind does not always follow a predictable path, and the victim was only able to report the incident when she felt safe and away from the accused's custody. The findings of the lower courts regarding the credibility of the rape victim are considered conclusive. On the accused-appellant's claim of revenge: The Court dismissed the accused-appellant's claim that the victim was seeking revenge. It reasoned that no woman in her right mind, especially a young girl, would fabricate charges of such a severe nature. The Court found no basis to give credence to the accused-appellant's assertion that the victim harbored a grudge due to his reprimands. On the proof of the victim's age: The Court found that the prosecution sufficiently proved the victim's age. A certification from the UCCP Office and a page from the UCCP Membership Book were presented, showing AAA was born on September 10, 1987, and baptized on June 5, 1988. The accused-appellant was listed as her father. The Court reiterated that baptismal certificates and similar documents are admissible to prove the age of a victim, and that entries in official records are prima facie evidence of their contents. On the twin qualifying circumstances of minority and relationship: The Court found that both circumstances were correctly appreciated by the lower courts. The accused-appellant admitted during the pre-trial conference that AAA was his daughter, thus establishing the relationship. The baptismal and membership records, as discussed, established AAA's minority at the time of the offenses. These twin circumstances qualified the crime of rape. On the penalty and damages: Considering that the rape was qualified by minority and relationship, the penalty of death would have been imposed prior to Republic Act No. 9346. However, with the prohibition of the death penalty, the lower courts correctly imposed reclusion perpetua. The Supreme Court, pursuant to its ruling in People v. Gambao, modified the awards for damages, granting P100,000.00 each for civil indemnity, moral damages, and exemplary damages for each count of rape, with legal interest.
Main Doctrine
The Supreme Court affirmed the conviction of the accused for five counts of rape, qualified by the minority and relationship of the victim, sentencing him to reclusion perpetua for each count. The Court also modified the damages awarded to the victim.