The Supreme Court affirmed the conviction of Rodolfo Pateño for five counts of rape against his daughter, emphasizing that the victim’s consistent testimony and the established familial relationship constitute sufficient evidence for conviction. This ruling underscores the gravity of familial abuse and ensures that perpetrators are held accountable, protecting vulnerable individuals within the family structure.
When Trust Becomes Betrayal: The Case of Rodolfo Pateño
This case revolves around Rodolfo Pateño, who was charged with multiple counts of raping his 14-year-old daughter, AAA. The Regional Trial Court (RTC) and the Court of Appeals (CA) both found him guilty beyond a reasonable doubt. Pateño appealed, arguing that AAA’s testimony was not credible and that the prosecution failed to prove her age at the time of the incidents. He claimed that AAA was motivated by revenge due to his disciplining her. The Supreme Court was tasked with reviewing the CA’s decision, focusing on the credibility of the victim’s testimony and the evidence presented to establish the qualifying circumstances of minority and familial relationship.
The Court addressed the accused-appellant’s argument that AAA’s testimony was improbable due to the consistent manner in which she described the rapes. Citing *People v. Solomon*, the Court noted that consistency in the victim’s account does not diminish her credibility. The Court stated:
Men are creatures of habit and are bound to adopt a course of action that has proven to be successful. As appellant was able to fulfill his lustful designs upon complainant the first time, it comes as no surprise that he would repeat the horrific acts when the circumstances obtaining in the first rape again presented themselves.
This highlights the psychological aspect of the crime, suggesting that a perpetrator may repeat actions that have previously been successful in subduing the victim. Furthermore, the Court acknowledged the victim’s delay in reporting the abuse, attributing it to her youth and the abuser’s position of authority. This perspective aligns with an understanding of trauma, where victims may not immediately disclose abuse due to fear, shame, or a lack of understanding of their situation.
Turning to the credibility of the witnesses, the Supreme Court reiterated the trial court’s advantage in assessing the demeanor and truthfulness of the witnesses. Given that the trial court had the opportunity to directly observe AAA’s testimony, its assessment was given significant weight. The Court also dismissed the accused-appellant’s claim that AAA fabricated the charges out of revenge. The Court emphasized that:
No woman in her right mind, especially a young girl, would fabricate charges of this nature and severity.
This statement reflects a recognition of the serious implications and emotional toll that such false accusations would entail, making them highly unlikely to be made without genuine cause.
The existence of the qualifying circumstances of minority and relationship were essential to the conviction. The accused-appellant admitted during the pre-trial conference that AAA was his daughter, establishing the familial relationship. To prove AAA’s age, the prosecution presented a certification from the United Church of Christ of the Philippines (UCCP) and a page from the UCCP Membership Book, both indicating that AAA was born on September 10, 1987. These documents were crucial in establishing that AAA was a minor at the time the crimes were committed.
The Court referenced Section 44, Rule 130 of the Rules of Court, which pertains to entries in official records, and found the UCCP Membership Book admissible as *prima facie* evidence of its contents. The Court underscored that:
Entries in public or official books or records may be proved by the production of the books or records themselves or by a copy certified by the legal keeper thereof.
This rule allows for the use of official records as evidence, provided they meet certain criteria for authenticity and reliability.
Considering the prohibition of the death penalty under Republic Act No. 9346, the lower courts correctly imposed the penalty of *reclusion perpetua* without eligibility for parole for each count of rape. The Court then addressed the issue of damages, modifying the CA’s award to align with current jurisprudence. Citing *People v. Gambao*, the Court increased the amounts awarded for civil indemnity, moral damages, and exemplary damages to P100,000.00 each per count of rape. The Court added that these damages would earn legal interest at the rate of 6% *per annum* from the date of finality of the judgment until fully paid.
FAQs
| What was the key issue in this case? | The key issue was whether the accused-appellant was guilty beyond reasonable doubt of five counts of rape against his minor daughter, considering the credibility of the victim’s testimony and the evidence presented to establish her age and the familial relationship. |
| What evidence was used to prove the victim’s age? | The prosecution presented a certification from the United Church of Christ of the Philippines (UCCP) and a page from the UCCP Membership Book indicating the victim’s date of birth. These documents served as *prima facie* evidence of her age at the time of the crime. |
| Why did the Court uphold the victim’s credibility despite the delay in reporting the abuse? | The Court acknowledged the victim’s youth and the accused-appellant’s position of authority, explaining that victims of abuse may delay reporting due to fear, shame, or a lack of understanding. This delay did not diminish her credibility. |
| What was the basis for the Court’s finding that the victim did not fabricate the charges out of revenge? | The Court stated that it is highly unlikely for a woman, especially a young girl, to fabricate such severe charges due to the serious implications and emotional toll that false accusations would entail. |
| What is the significance of the case *People v. Solomon* cited in this decision? | *People v. Solomon* supports the view that consistency in a victim’s testimony regarding the manner of rape does not diminish her credibility. It suggests that perpetrators often repeat actions that have previously been successful in subduing the victim. |
| What penalty was imposed on the accused-appellant, and why? | The accused-appellant was sentenced to *reclusion perpetua* without eligibility for parole for each count of rape. The death penalty, which would have been the appropriate penalty given the qualifying circumstances, was prohibited by Republic Act No. 9346. |
| What types of damages were awarded to the victim, and how were they calculated? | The victim was awarded civil indemnity, moral damages, and exemplary damages, each amounting to P100,000.00 per count of rape. These amounts were based on the guidelines set in *People v. Gambao*, and all damages were to earn legal interest at the rate of 6% *per annum* from the date of finality of the judgment. |
| How does Section 44, Rule 130 of the Rules of Court, apply in this case? | Section 44, Rule 130 allows for the use of entries in official records as *prima facie* evidence of the facts stated therein. The UCCP Membership Book was admitted as evidence of the victim’s age under this rule. |
This case underscores the judiciary’s commitment to protecting vulnerable individuals from familial abuse, ensuring that perpetrators are held accountable for their actions. The decision serves as a reminder of the importance of credible testimony and the admissibility of official records in establishing the elements of the crime.
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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. RODOLFO PATEÑO Y DAYAPDAPAN, G.R. No. 209040, December 09, 2015