People v. Pada

G.R. No. 117641 (September 16, 1996)

Facts:

On August 28, 1991, Magencio Pada, alias "Menciong," was charged with the crime of rape by Angeles Mangala, the mother of the victim, Siodaleyte Mangala, a twelve-year-old girl. The incident allegedly occurred on August 19, 1991, at around 9:00 AM in Barangay San Pedro, Matalom, Leyte. Siodaleyte was at a store buying paper when the accused called her to buy food for him at the market, giving her P25.00 for the purchase. Upon her return, he pulled her into his house, brandished a knife, and threatened to kill her parents if she did not comply with his demands. Under duress, Siodaleyte undressed and was subsequently raped by the accused, who then threatened her again to keep the incident a secret.

A week later, after hearing rumors about her daughter, Siodaleyte's mother confronted her, leading to the revelation of the sexual abuse. A medical examination conducted on August 27, 1991, confirmed lacerations in Siodaleyte's hymen and swelling in her labia and clitoris, indicating that consummated rape had occurred.

The accused denied the allegations, claiming he was at the market working all day and asserting that he could not have committed the crime due to a paralysis in his left hand since 1986.

The trial court found Magencio Pada guilty of rape and sentenced him to reclusion perpetua, along with a civil indemnity of P30,000.00 to the victim.

Legal Issues:

  1. Whether the prosecution established the guilt of the accused beyond a reasonable doubt.
  2. Whether the circumstances surrounding the crime warranted the imposition of the death penalty or a lesser penalty.
  3. The appropriate amount of civil indemnity to be awarded to the victim.

Arguments:

Prosecution:

  • The prosecution argued that the victim's testimony was straightforward and credible, supported by medical evidence of physical trauma consistent with rape.
  • The use of a knife and threats against the victim's parents constituted sufficient intimidation, fulfilling the elements of rape as defined under Article 335 of the Revised Penal Code.
  • The victim's silence and lack of immediate reporting were attributed to fear, not consent.

Defense:

  • The defense contended that the prosecution failed to prove the crime of rape, arguing that the victim did not resist or shout for help during the incident.
  • The accused claimed an alibi, stating he was at the market during the time of the alleged crime and could not have committed it due to his physical limitations.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that the prosecution had established the accused's guilt beyond a reasonable doubt. The court emphasized that the victim's lack of resistance did not negate the presence of force and intimidation, particularly given the accused's threats and the use of a deadly weapon. The court noted that the victim's age (twelve years old) and the accused's age (sixty-three years old) further underscored the power imbalance and the intimidation involved.

The court also addressed the issue of civil indemnity, increasing it from P30,000.00 to P50,000.00 due to the victim's age at the time of the crime, in line with established jurisprudence regarding the civil liability for rape.

Significant Legal Principles Established:

  1. The presence of intimidation, even in the absence of physical resistance, is sufficient to establish the crime of rape, particularly when threats involve harm to the victim's family.
  2. The credibility of a minor's testimony in cases of sexual abuse is often upheld, especially when corroborated by medical evidence.
  3. The age of the victim is a significant factor in determining the severity of the penalty and the amount of civil indemnity in cases of rape.