The Supreme Court affirmed the conviction of Victor P. Padit for the crime of rape, emphasizing the protection of children and clarifying the definition of carnal knowledge in statutory rape cases. This decision underscores that even the slightest penetration constitutes consummated rape, especially when the victim is a minor. The ruling reinforces the importance of giving full weight to the testimonies of child-victims and ensures that perpetrators of sexual abuse against children are brought to justice.

A Child’s Voice: Proving Rape Through Testimony and Medical Evidence

In People of the Philippines v. Victor P. Padit, the central issue revolved around the conviction of the accused for the rape of a four-year-old girl. The prosecution presented the victim’s testimony, supported by medical evidence, detailing how the accused, a neighbor and relative, brought her into his house and sexually molested her. The accused denied the allegations, claiming his wife was with him at the time of the incident. The Regional Trial Court (RTC) found the accused guilty, a decision which was affirmed with modification by the Court of Appeals (CA). The Supreme Court then reviewed the case to determine whether the prosecution had successfully proven the accused’s guilt beyond a reasonable doubt.

The Supreme Court began by addressing a technical error in the Information, which cited Article 335 of the Revised Penal Code (RPC), a provision already repealed by the Anti-Rape Law of 1997 (RA 8353). RA 8353 reclassified rape as a crime against persons, with the relevant provisions now found in Articles 266-A to 266-D of the RPC. The Court clarified that while the specific provision cited was incorrect, the facts alleged in the Information clearly described acts punishable under Article 266-A, in relation to Article 266-B, of the RPC, as amended.

According to Article 266-A, rape is committed when a man has carnal knowledge of a woman under specific circumstances. One such circumstance is when “the offended party is under twelve (12) years of age or is demented, even though none of the circumstances mentioned above be present.” Article 266-B specifies that rape under paragraph 1 of Article 266-A shall be punished by reclusion perpetua and that the death penalty shall also be imposed if the crime of rape is committed with any aggravating/qualifying circumstances, such as when “the victim is a child below seven (7) years old.”

The Court emphasized the importance of the victim’s testimony, particularly given her young age. Testimonies of child-victims are given full weight and credit because, as the Court stated,

“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.”

The Court also acknowledged the vulnerability of children and the shame they would endure if they were to falsely testify about such a traumatic experience. Therefore, youth and immaturity are generally seen as indicators of truth and sincerity.

One of the main arguments of the accused was that the prosecution failed to prove carnal knowledge, as the victim stated that the accused merely rubbed his penis against her vagina. The Court, however, rejected this argument, stating that a four-year-old child is not expected to have comprehensive knowledge of sexual intercourse. The legal definition of **carnal knowledge** includes any sexual bodily connection with a woman, and even the slightest penetration of the female genitalia is sufficient to consummate the act of rape.

Quoting jurisprudence, the Court pointed out,

“a mere touching of the external genitalia by the penis capable of consummating the sexual act already constitutes consummated rape.”

The victim testified that she felt pain when the accused rubbed his penis against her vagina, and the Court has previously held that a victim’s testimony of feeling pain is sufficient to establish rape. Furthermore, the Court noted that the victim continued to experience severe pain when her mother bathed her afterward, suggesting that the pain resulted from penetration and not just superficial rubbing.

Supporting the victim’s testimony was the medical evidence indicating a slight hymenal abrasion upon examination of her vulva. The Court affirmed that both the victim’s positive testimony and the medical findings supported the conclusion that penetration, however slight, had occurred. Even if the testimony of the victim’s mother was considered hearsay, the Supreme Court found that non-admission would not be enough to save the day for the accused-appellant because such testimony served merely to corroborate the victim’s statement.

Furthermore, the Court dismissed the argument that the victim’s mother’s testimony was hearsay. Hearsay evidence is defined as evidence not based on the personal knowledge of the witness, but on information learned from a third party not sworn as a witness. Here, the declarant, the victim herself, testified and was cross-examined by the defense, giving the trial court the opportunity to observe her demeanor and assess her credibility. Thus, her mother’s testimony was deemed admissible.

The argument that the accused had never previously molested the victim during her visits to his house was deemed irrelevant. The Court noted that the decisive factor is whether the commission of the crime has been sufficiently proven. Any discrepancy or inconsistency in a witness’s testimony must relate to significant facts indispensable to the guilt or innocence of the accused to warrant acquittal, which was not the case here.

Given the victim’s age, the crime was considered **statutory rape**, which the Court defined as carnal knowledge of a woman below twelve years of age. The accused was found guilty of statutory rape, and the penalty was determined based on the RPC as amended. While Article 266-B provides for the death penalty if the victim is below seven years old, the court correctly imposed reclusion perpetua due to Republic Act No. 9346, which prohibits the imposition of the death penalty in the Philippines. The Court modified the lower court’s decision to explicitly state that the sentence of reclusion perpetua is without eligibility for parole.

In addition to the prison sentence, the Court upheld the award of damages to the victim. The RTC awarded P75,000.00 as civil indemnity and P75,000.00 as moral damages, which the CA supplemented with an additional P30,000.00 as exemplary damages. The Supreme Court confirmed that an award of civil indemnity is mandatory upon a finding of rape, and moral damages are automatically awarded without needing proof of mental or physical suffering. Exemplary damages are awarded to set a public example and protect young people from sexual abuse.

To align with prevailing jurisprudence, the Court also ordered the accused to pay interest of six percent (6%) per annum on all damages awarded, from the finality of the judgment until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution proved beyond reasonable doubt that the accused was guilty of raping a four-year-old girl. The court also addressed the technicality of citing an outdated law in the Information.
What is the definition of carnal knowledge?	Carnal knowledge is defined as the act of a man having sexual bodily connections with a woman. Even the slightest penetration of the female genitalia is sufficient to consummate the act of rape.
What is statutory rape?	Statutory rape is carnal knowledge of a woman below twelve years of age, regardless of whether force, threat, or intimidation is present.
Why is the testimony of a child-victim given special weight?	Child-victims are considered more credible due to their youth and immaturity, making them less likely to fabricate a story of sexual abuse. Their testimonies are given full weight, assuming they are of sound mind and capable of recounting the events accurately.
What kind of evidence is needed to prove rape?	The victim’s testimony, if credible and consistent, is sufficient to prove rape. Medical evidence, such as findings of hymenal abrasion, can corroborate the victim’s account and strengthen the prosecution’s case.
What damages are awarded to a rape victim?	Rape victims are typically awarded civil indemnity, moral damages, and exemplary damages. Civil indemnity is a mandatory award, while moral damages are awarded automatically without proof of suffering. Exemplary damages are given to set a public example.
What is the penalty for statutory rape in the Philippines?	The penalty for statutory rape, where the victim is below seven years old, is reclusion perpetua without eligibility for parole, as the death penalty is prohibited in the Philippines.
What is the effect of Republic Act No. 9346 on rape cases?	Republic Act No. 9346 prohibits the imposition of the death penalty in the Philippines. As a result, courts impose the penalty of reclusion perpetua without eligibility for parole in rape cases where the death penalty would otherwise be applicable.

The Supreme Court’s decision in People v. Padit underscores the justice system’s commitment to protecting children and ensuring that those who commit heinous acts of sexual abuse are held accountable. By clarifying the definition of carnal knowledge and emphasizing the importance of child-victim testimonies, the Court reinforces the legal framework designed to safeguard the well-being of the most vulnerable members of society.

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: People v. Padit, G.R. No. 202978, February 01, 2016