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PP vs. Padilla (My Digest)

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PP. VS.

PADILLA
Facts: An Information was filed against appellant, Armando Nicolas Padilla, charging him
with the crime of statutory rape. On arraignment, appellant pleaded not guilty. Pre-trial
conference followed. Thereafter, trial ensued. the Lower Court finds the appellant
GUILTY beyond reasonable doubt of the crime of Statutory Rape and sentenced him the
capital penalty of DEATH. After a review of the case, the CA affirmed the lower courts
decision. Hence, the appeal to the SC. The appellant argued that the prosecution was not
able to prove the victims minority. Aside from the testimonies of prosecution
witnesses, coupled with appellant's absence of denial, no independent substantial
evidence was presented to prove the age of the victim. Neither was it shown by the
prosecution that the said documents had been lost, destroyed, unavailable or were
otherwise totally absent.
Issue: Whether or not the testimonies of prosecution witnesses, coupled with appellants
absence of denial are considered as BEST EVIDENCE.
Held: No. the settled rule is that there must be independent evidence proving the age of
the victim, other than the testimonies of the prosecution witnesses and the absence of
denial by appellant. The victim's original or duly certified birth certificate, baptismal
certificate or school records would suffice as competent evidence of her age. Appellants
failure to object to the testimony of the victim, regarding her age, the Court has held that
the failure of the accused to object to the testimonial evidence regarding the rape victims
age shall not be taken against him. Even the appellant's implied admission of the victim's
age, in the absence of any supporting independent evidence, may not be considered
sufficient to prove her age. As the qualifying circumstance of minority alters the nature of
the crime of rape and increases the penalty thereof, it must be proved with equal certainty
and clearness as the crime itself.

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