In the case of People of the Philippines vs. Guillermo B. Cadano, Jr., the Supreme Court affirmed the conviction of the accused for three counts of statutory rape, highlighting the unwavering protection afforded to children under Philippine law. This decision underscores the principle that consent is irrelevant when the victim is below the age of twelve, emphasizing the State’s duty to safeguard the most vulnerable members of society. The ruling serves as a stern warning against those who prey on children, reinforcing the severe consequences of such heinous acts and ensuring that justice is served for the victims.

A Betrayal of Trust: When a Guardian Violates a Child’s Innocence

The case revolves around Guillermo B. Cadano, Jr., who was charged with three counts of statutory rape against AAA, his common-law spouse’s daughter. The incidents occurred between 1996 and 2000, spanning both the old and amended provisions of the Revised Penal Code concerning rape. The central legal question is whether the prosecution successfully proved beyond reasonable doubt that Cadano committed the acts, warranting his conviction.

The prosecution presented AAA’s testimony, detailing the harrowing experiences she endured. Corroborating this was the medico-legal report, which confirmed penetration. Cadano, in his defense, denied the allegations, claiming that the charges were fabricated due to family problems. However, the trial court and subsequently the Court of Appeals found AAA’s testimony credible and reliable, leading to Cadano’s conviction. The Supreme Court, in its review, upheld the lower courts’ decisions, emphasizing the importance of protecting children from sexual abuse.

The legal framework for this case involves both the old and amended provisions of the Revised Penal Code (RPC). The first two rape incidents occurred before the passage of Republic Act No. 8353, also known as the “Anti-Rape Law of 1997.” Therefore, Article 335 of the RPC, which was then in effect, applies to these incidents. This article defined rape as:

Article 335. When and how rape is committed. – Rape is committed by having carnal knowledge of a woman under any of the following circumstances:

x x x x

3. When the woman is under twelve years of age, even though neither of the circumstances mentioned in the two next preceding paragraphs shall be present.

The crime of rape shall be punished by reclusion perpetua.

The third rape incident, however, occurred after the enactment of RA 8353. Thus, the amended provisions of the RPC, specifically Articles 266-A and 266-B, are applicable. These articles state:

Art. 266-A. Rape,When And How Committed. – Rape is committed –

1) By a man who shall have carnal knowledge of a woman under any of the following circumstances:

x x x x

d) When the offended party is under twelve (12) years of age or is demented, even though none of the circumstances mentioned above be present.

x x x x

Art.266-B. Penalties. – Rape under paragraph 1 of the next preceding article shall be punished by reclusion perpetua.

x x x x

The death penalty shall also be imposed if the crime of rape is committed with any of the following aggravating/qualifying circumstances:

1) When the victim is under eighteen (18) years of age and the offender is a parent, ascendant, step-parent, guardian, relative by consanguinity or affinity within the third civil degree, or the common-law spouse of the parent of the victim;

x x x x

The Supreme Court emphasized that statutory rape is committed when there is sexual intercourse with a person below 12 years of age. In such cases, consent is irrelevant. The elements that the prosecution must prove are:

1. The age of the complainant.
2. The identity of the accused.
3. The sexual intercourse between the accused and the complainant.

All these elements were sufficiently proven in Cadano’s case. AAA’s birth certificate established her age, her testimony identified Cadano, and the medico-legal report corroborated the sexual intercourse.

Building on this principle, the Court highlighted the weight given to the testimony of child victims. As the Court stated,

[t]estimonies of child-victims are normally given full weight and credit, since when a girl, particularly if she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape has in fact been committed. When the offended party is of tender age and immature, courts are inclined to give credit to her account of what transpired, considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified is not true. Youth and immaturity are generally badges of truth and sincerity. A young girl’s revelation that she had been raped, coupled with her voluntary submission to medical examination and willingness to undergo public trial where she could be compelled to give out the details of an assault on her dignity, cannot be so easily dismissed as mere concoction.

This underscores the judiciary’s sensitivity and protective stance towards child victims of sexual abuse. Given the vulnerability and potential trauma, the courts prioritize their well-being and give significant weight to their testimonies.

The Court also addressed the penalties imposed. While the qualifying circumstance of Cadano being the common-law spouse of AAA’s mother could have aggravated the third rape incident, potentially warranting the death penalty under Article 266-B, the abolition of the death penalty through Republic Act No. 9346 limited the penalty to reclusion perpetua. However, the Court noted discrepancies in the damages awarded by the lower courts. The amounts were adjusted to reflect the appropriate compensation for each count of statutory rape, considering the applicable laws at the time of each incident. For the first two counts, which fall under the old rape provision (Article 335 of the RPC), the Court awarded P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as exemplary damages for each count. For the third count, which falls under the amended provisions (Articles 266-A and 266-B), the Court awarded P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages. These adjustments ensure that the victim receives adequate compensation for the trauma and suffering endured.

This case illustrates the commitment of Philippine law to protect children from sexual abuse and exploitation. The unwavering application of the law, coupled with the courts’ sensitivity towards child victims, sends a strong message that such crimes will not be tolerated. The decision in People vs. Cadano reinforces the legal framework designed to safeguard the rights and well-being of the most vulnerable members of society, ensuring that perpetrators are brought to justice and victims are given the support and compensation they deserve.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully proved beyond reasonable doubt that Guillermo B. Cadano, Jr. committed statutory rape against AAA, his common-law spouse’s daughter, on three separate occasions. The incidents spanned both the old and amended provisions of the Revised Penal Code concerning rape.
What is statutory rape?	Statutory rape is defined as sexual intercourse with a person below a certain age, regardless of consent. In the Philippines, this age is 12 years old.
What elements must be proven to convict someone of statutory rape?	To convict someone of statutory rape, the prosecution must prove: (1) the age of the complainant, (2) the identity of the accused, and (3) the sexual intercourse between the accused and the complainant.
What is the significance of Republic Act No. 8353 in this case?	Republic Act No. 8353, or the Anti-Rape Law of 1997, amended the provisions of the Revised Penal Code concerning rape. Some of the incidents in this case occurred before RA 8353, while others occurred after, leading to different legal provisions being applied.
What penalties were imposed on Cadano?	Cadano was sentenced to reclusion perpetua for each count of statutory rape. Additionally, he was ordered to pay civil indemnity, moral damages, and exemplary damages to the victim, AAA.
How did the Court consider the testimony of the child victim?	The Court gave significant weight to the testimony of AAA, emphasizing that testimonies of child victims are normally given full weight and credit. The Court recognized the vulnerability and potential trauma of the victim, thus prioritizing her well-being and testimony.
What is the effect of Republic Act No. 9346 on this case?	Republic Act No. 9346, which prohibits the imposition of the death penalty in the Philippines, affected the penalty for the third rape incident. Although the qualifying circumstance of the offender being the common-law spouse of the victim’s mother could have warranted the death penalty, RA 9346 limited the penalty to reclusion perpetua.
What damages were awarded to the victim?	For the first two counts, AAA was awarded P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as exemplary damages for each count. For the third count, she was awarded P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages.

The Supreme Court’s decision in this case underscores the importance of protecting children from sexual abuse and exploitation. The ruling serves as a reminder of the legal consequences for those who commit such heinous crimes, ensuring that justice is served and victims receive the support they need to heal and recover.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. GUILLERMO B. CADANO, JR., ACCUSED-APPELLANT, G.R. No. 207819, March 12, 2014