**People of the Philippines vs. Pedro Buado, Jr. y Cipriano: Conviction for Two Counts of Rape Against His Own Daughters**
### Facts:
This case involves the horrific acts of Pedro Buado, Jr., who was convicted of raping his two minor daughters over several years within their family home. The criminal charges were filed in Valenzuela City, Metro Manila, under Criminal Case No. 912-V-99 for the rape of his ten-year-old daughter, AAA, in April 1999, and Criminal Case No. 974-V-99 for the rape of his eight-year-old daughter, BBB, in November 1999. Buado pleaded not guilty.
The prosecution presented eight witnesses, including the victims, their family members, and medical professionals who examined them. Evidence revealed that Buado summoned AAA from a party and raped her in April 1999, an act she disclosed to her mother, CCC, after the event. This pattern of abuse began when AAA was in grade one and continued until she was in grade four. CCC and AAA eventually sought help from the National Bureau of Investigation (NBI) in June 1999.
BBB’s abuse occurred later, in November 1999, as detailed by her and their older sister DDD. Buado instructed BBB to undress and raped her using cooking oil as a lubricant. BBB disclosed the rape to DDD, who in turn informed their mother. Medical examinations of both victims corroborated their accounts of sexual abuse.
Buado, defending himself, blamed his drug addict son for the alleged rape of BBB and claimed his wife concocted the charges out of anger and jealousy.
Both the Regional Trial Court (RTC) and the Court of Appeals (CA) found Buado guilty, initially prescribing the death penalty which was later modified to reclusion perpetua due to the abolition of the death penalty, augmented with fines and damages.
### Issues:
1. Whether Buado’s guilt was established beyond reasonable doubt.
2. The applicability of the death penalty or its commutation to reclusion perpetua based on the prohibition of imposing the death penalty.
3. The credibility of the victims’ testimonies, especially considering the delay in reporting the offenses.
4. The establishment of qualifying circumstances, particularly the relationship and the minority of the victims.
### Court’s Decision:
The Supreme Court affirmed Buado’s conviction, finding no merit in his appeal. It ruled the testimonies of the victims as credible, corroborated by medical evidence and witness testimonies. The Court dismissed Buado’s denials and justification, emphasizing the believable, consistent, and detailed accounts of the victims.
The delay in reporting the crimes was seen as reasonable given the victims’ fear of retaliation from Buado, alongside his history of violence. The Court also tackled the absence of a direct objection to the victims’ age, noting it does not negate the accused’s awareness and the establishment of guilt beyond a reasonable doubt.
On sentencing, the Court modified the CA’s decision, setting the penalties to reclusion perpetua without eligibility for parole due to the prohibition of the death penalty, ensuring the imposition of civil liabilities aligned with the severity of the crimes.
### Doctrine:
The case reiterated the grave offensive nature of rape, especially so when committed against one’s children, establishing stringent measures for its punishment even amidst legislative changes regarding the death penalty. It highlighted the paramount importance of testimonial credibility, the relevance of psychological impact over physical evidence in sexual abuse cases, and the procedural requirements in establishing age and relationship as aggravating/qualifying circumstances.
### Class Notes:
– The best evidence in proving rape lies in the credible, consistent testimony of the victim.
– Delays in reporting sexual crimes, especially by minors, do not necessarily detract from the credibility of the accusations, given potential fears of retaliation.
– For qualifying circumstances of minority and relationship to aggravate a rape charge, such facts must be both alleged and proven in accordance with the guidelines established in previous jurisprudence.
– The prohibition against the death penalty under R.A. No. 9346 does not affect the imposition of corresponding civil liabilities.
### Historical Background:
This decision reflects the legal landscape in the Philippines post-abolition of the death penalty (through the enactment of R.A. No. 9346 in 2006), showcasing the judiciary’s adaptation in sentencing capital offenses and the continuous effort to protect the rights and welfare of minors and sexual abuse victims. It encapsulates the tension between retributive justice and human rights considerations in penal law.
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