The Supreme Court affirmed the conviction of Alfredo Natan for statutory rape, emphasizing that having carnal knowledge of a child under 12 constitutes a violation, regardless of force or consent, as the law presumes a child’s inability to discern or consent. This ruling underscores the state’s duty to protect children from sexual abuse, reinforcing that the tender age of the victim eliminates any question of consent. It serves as a crucial safeguard for children’s rights and well-being, highlighting the severe consequences for those who exploit their innocence.

Alfredo Natan: When Godfathers Betray Childhood Trust

In 1992, Alfredo Natan was accused of raping “Maria,” a 6-year-old girl under his care as her godfather. Maria, after years of silence, reported the abuse, leading to Natan’s prosecution. The case unfolded in the Regional Trial Court of Hilongos, Leyte, where the court found Natan guilty of statutory rape based on Maria’s candid testimony and medical evidence confirming healed hymenal lacerations. This evidence indicated that her physical condition aligned with the claims of sexual abuse. The defense contested the claims, citing inconsistencies in Maria’s statements, such as whether Maria or Natan removed Maria’s underwear. Natan presented an alibi, claiming he was in Tacloban and Samar during the times the rape occurred.

However, the trial court dismissed Natan’s defense. On appeal, the Court of Appeals affirmed the trial court’s decision but modified the penalty to reclusion perpetua due to Republic Act No. 9346 or the Anti-Death Penalty Law. Moral and exemplary damages were also increased. Natan appealed the decision, questioning Maria’s consistency and seeking to overturn his conviction. The Supreme Court was tasked with deciding whether the evidence sufficiently proved Natan’s guilt beyond reasonable doubt and if the proper penalty was imposed, considering the circumstances of the crime and the laws in effect at the time.

The Supreme Court underscored the definition of statutory rape, which, according to paragraph 3, Article 335 of the Revised Penal Code, occurs when a man has carnal knowledge of a woman under 12 years of age. In such cases, the element of force or the lack of resistance from the woman is irrelevant. Consent is immaterial because the law considers a child incapable of giving legal consent. The focus is on protecting children and preventing the violation of their innocence due to their inability to understand or resist such acts.

Under paragraph 3, Article 335 of the Revised Penal Code, statutory rape is committed by having carnal knowledge of a woman below 12 years of age. In this specie of rape, neither force by the man nor resistance from the woman forms an element of the crime and apparent consent thereto will be of no avail, any more than in the case of a child who may actually consent but who by law is conclusively held incapable of legal consent. The law presumes that the victim on account of her tender years, does not and cannot have a will of her own. The heart of the matter is the violation of a child’s incapacity to discern evil from good.

Minor inconsistencies in Maria’s testimony, such as who removed her panty or the exact date of the incident, were deemed inconsequential by the Court. The crucial point was Maria’s unwavering declaration and positive identification of Natan as the perpetrator. Such consistency in identifying the abuser holds greater weight than discrepancies in minor details. As testimonies of children are seen as more credible when there is no motive to fabricate charges against the offender. Fabricating tales of sexual defloration could carry severe consequences for the accused and cannot be easily dismissed.

Regarding the appropriate penalty, the Supreme Court noted that since the crime was committed in 1992, prior to the effectivity of Republic Act No. 7659 on December 31, 1993, the fact that the victim was below seven years old could not be considered an aggravating circumstance to impose the death penalty. The proper penalty remained reclusion perpetua. The Court also clarified that the victim was entitled to civil indemnity, automatically imposed for the commission of rape, and moral damages. Moreover, the Court awarded Php 50,000.00 as civil indemnity and Php 50,000.00 as moral damages.

FAQs

What was the key issue in this case?	The key issue was whether Alfredo Natan was guilty of statutory rape and whether the proper penalty was imposed, given the age of the victim and the laws in effect at the time of the crime.
What is statutory rape according to Philippine law?	Statutory rape is defined under Article 335 of the Revised Penal Code as carnal knowledge of a woman below 12 years of age. In such cases, neither force nor resistance is an element of the crime.
Why was the death penalty not imposed in this case?	Although the trial court initially imposed the death penalty, the Supreme Court clarified that because the crime occurred before Republic Act No. 7659 took effect, the death penalty was not applicable, and the proper penalty was reclusion perpetua.
What damages were awarded to the victim?	The victim, Maria, was awarded Php 50,000.00 as civil indemnity, which is automatically imposed for rape, and Php 50,000.00 as moral damages.
What did the Court say about inconsistencies in the victim’s testimony?	The Court found the minor inconsistencies, such as who removed Maria’s panty or the precise date of the rape, inconsequential and that the important issue was her identification of the offender and consistent claim of rape.
What is the significance of the victim’s age in this case?	The victim’s age is significant because the law presumes that a child under 12 is incapable of giving legal consent to sexual acts. This eliminates the need to prove force or lack of consent.
What was the impact of Republic Act No. 9346 on this case?	Republic Act No. 9346, or the Anti-Death Penalty Law, influenced the Court of Appeals to modify the trial court’s initial decision, changing the penalty from death to reclusion perpetua.
Why did the Court affirm the conviction despite the defense’s alibi?	The Court did not find the defense’s alibi credible, noting that it was not impossible for the appellant to be present at the crime scene.

The Supreme Court’s decision in People v. Natan serves as a testament to the justice system’s commitment to protect the most vulnerable members of society. It reinforces that statutory rape is a grave offense, with serious consequences for perpetrators. This ruling continues to safeguard children from exploitation and abuse.

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 of the Philippines vs. Alfredo Natan, G.R. No. 181086, July 23, 2008