G.R. No. 267163 - People vs. Eduardo Dela Cruz y Tolentino

Eduardo Dela Cruz y Tolentino (Dela Cruz) was charged with rape under Criminal Case No. 3492-2015.
The Information alleged that on or about February 25, 2015, at around 6:30 p.m., in the Municipality of xxxxxxxxxxx, Province of xxxxxxxxxxx, Philippines, Dela Cruz willfully, unlawfully, and feloniously, by means of force and intimidation, had carnal knowledge of AAA, a special child, a minor 16 years old, against her will.
The case was raffled to the Regional Trial Court, Branch xxxxxxxxxxx.

Upon arraignment, Dela Cruz pleaded not guilty.
The prosecution presented AAA, the victim, while the defense presented Dela Cruz as a witness.

AAA was born on September 10, 1998, making her approximately 16 years old at the time of the incident.
She testified that on February 25, 2015, Dela Cruz called her into a Born Again church and committed acts of sexual abuse, including touching her breast and vagina, inserting his finger, removing her clothing, kissing her vagina, and finally having sexual intercourse with her.
In her Sworn Statement dated February 26, 2015, AAA described the acts in clear terms confirming sexual acts.
A medical certificate dated February 26, 2015, by Dr. Myra Paril-Gana, indicated AAA’s hymen was intact and showed no signs of bleeding, abrasions, or erythema.
The defense admitted the existence of the medical certificate.
The court treated AAA as a child witness based on her mental age discerned from her appearance and demeanor.

Dela Cruz denied the charges, stating he was cutting coconut husks when AAA, appearing mentally challenged, was roaming and pulling down her shorts.
He claimed he only pulled up AAA's shorts to prevent further exposure.
AAA’s mother accused him of rape and called the police, leading to his detention.
On cross-examination, Dela Cruz admitted knowledge of AAA’s mental condition and that she used to call him "Uncle Edward."

The trial court found Dela Cruz guilty beyond reasonable doubt of statutory rape under Article 266-A paragraph 1(d) of the Revised Penal Code.
It ruled that all elements of statutory rape were present, and the intact hymen did not negate the crime.
Dela Cruz was sentenced to reclusion perpetua and ordered to pay PHP 30,000 each as civil indemnity, moral damages, and exemplary damages.
His motion for reconsideration was denied.

The Court of Appeals affirmed the conviction but modified damages to PHP 75,000 each and imposed 6% interest per annum from finality until full payment.

Whether there was rape committed by Eduardo Dela Cruz against AAA.
Whether the victim's mental age or intellectual disability supports the conviction for statutory rape under Article 266-A(1)(d) of the Revised Penal Code.
Whether the lack of medical or clinical evidence identifying the victim’s mental age precludes conviction for statutory rape.
The appropriateness of the penalty and damages awarded.
Whether the qualifying circumstance of the offender’s knowledge of the victim's mental disability must be alleged in the Information to be appreciated.