G.R. No. L-7425 - Almeda vs. Court of Industrial Relations

The victim, referred to as AAA, is an 18-year-old woman with significant mental retardation, having an IQ of 43 and a mental age of approximately 5 years and 6 months.
The accused, Gilbert Castro y Aguilar, was 22 years old at the time of the incidents and is a second cousin and neighbor of AAA, with their residences being only a few meters apart.
Due to her limited learning capacity, AAA had not even completed Grade 1 and was unable to read or write.

First Incident: Occurred on February 5, 2002, where the accused is said to have committed the act under a mango tree.
Second Incident: Occurred on November 27, 2002, with a similar modus operandi as the first.

Criminal Case No. 771-M-2003 – alleging rape with the use of a bladed weapon on February 5, 2002.
Criminal Case No. 772-M-2003 – alleging a subsequent rape on November 27, 2002, committed by means of force, violence, and intimidation.

The medico-legal examination revealed that although AAA was in a non-virgin state, there were no signs suggestive of any trauma at the time of the examination.

AAA testified categorically identifying the accused as her assailant on both occasions.
AAA’s account detailed explicit acts including stripping off her clothes and the manner in which the assault was committed under a mango tree using banana leaves as a support.
Witness BBB, identified as AAA’s uncle and a neighbor, corroborated the second incident by stating he personally witnessed the act.
A psychological report by Dr. Nimia C. de Guzman confirmed AAA’s condition as moderately mentally retarded.
Testimonies of AAA’s mother (XYZ) and the psychologist further substantiated the victim’s incapacity.

Castro denied the allegations outright, challenging the credibility of the victim’s testimony.
He asserted alibi defenses: claiming that during the time of the first incident he was at a funeral wake and, during the second, he was with his sister and later in a field harvesting palay.
He argued that inconsistencies in the victim’s statements, highlighted during cross-examination, cast doubt on her credibility.

At the trial level, the Regional Trial Court (RTC) acquitted Castro on the first count (involving the use of a bladed weapon), finding insufficient evidence.
However, Castro was convicted on the second count for rape, with the RTC sentencing him to reclusion perpetua and imposing damages on the victim.
The Court of Appeals (CA) subsequently affirmed the RTC’s conviction (with modifications in the award for damages), ordering Castro to pay civil indemnity, moral damages, and exemplary damages.
The prosecution’s evidence—particularly the clinical, psychological, and eyewitness testimonies—played a pivotal role in establishing the elements required for a rape conviction.

Whether the evidence presented was sufficient to establish beyond reasonable doubt that the accused had carnal knowledge of AAA.
Whether the clinical and psychological evidence effectively corroborated the victim’s claim of being mentally retarded and hence incapable of consent.

Whether the minor inconsistencies in AAA’s testimony were material to the case and enough to create reasonable doubt about the occurrence of the crime.
The weight to be given to the corroborative testimonies of BBB (the neighbor/uncle) and other witnesses (such as XYZ and the psychologist).

Whether the accused’s alibi (attending a funeral wake and having lunch with his sister) was credible and substantiated by any corroborative evidence or testimony.
Whether the defense’s reliance on the alleged contradictions in the victim’s statements is sufficient to negate the established elements of the crime.

Whether the imposition of reclusion perpetua is proper in light of the crime committed, especially given the aggravating factor of the victim’s mental incapacity.
Whether the adjustment in the award for civil indemnity, moral damages, and exemplary damages is justified under the prevailing legal standards and jurisprudence.