Case Digest (G.R. No. 208013) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Edgar Allan Corpuz y Flores (G.R. No. 208013, July 3, 2017), accused-appellant Edgar Allan Corpuz was charged in four Informations before Branch 50 of the Regional Trial Court (RTC), Villasis, Pangasinan, with four counts of Simple Rape under Article 266-A, paragraph 1, in relation to Article 266-B of the Revised Penal Code, as amended by R.A. 8353. The victim, AAA, was a 14-year-old female with a mental age of 5 years and 8 months at the time of the alleged offenses in late 2002. Prosecution witnesses included AAA’s relatives, police officers, psychiatrists, and psychologists. Medical evidence established healed hymenal lacerations and a three-to-four-month pregnancy. A neuropsychiatric evaluation confirmed moderate to mild mental retardation, rendering AAA incapable of giving informed consent. DNA testing, conducted at the appellant’s request, demonstrated a 99.9999% probability that Edgar Allan Corpuz was the biological father of AAA’s child. Case Digest (G.R. No. 208013) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Edgar Allan Corpuz y Flores (Accused-Appellant) was charged with four counts of simple rape under Art. 266-A, par. 1, in relation to Art. 266-B of the Revised Penal Code, as amended by R.A. 8353.
- The victim, AAA, was 14 years old at the time of alleged offenses, with a mental age of approximately five years and eight months.
- Criminal Information and Arraignment
- Informations alleged that between October and December 2002 in Villasis, Pangasinan, Allan raped AAA by force, violence, and intimidation, without her consent.
- Upon arraignment, Allan pleaded not guilty, and a joint trial on the merits ensued.
- Prosecution Evidence
- Family and lay witnesses (BBB, CCC, GGG, EEE) recounted AAA’s pregnancy discovery, her statements naming Allan, and her admission at Asingan Community Hospital.
- Medical evidence: Dr. Araos-Liberato’s medico-legal certificate revealed healed hymenal lacerations and a positive pregnancy test corresponding to a three- to four-month gestation.
- Neuropsychiatric evaluations:
- Psychologist Brenda Tablizo (Feb. 2003) found AAA’s mental age of 5y8m and IQ 42 (moderate mental retardation).
- Dr. Rachel Acosta (prior to testimony) found mild mental retardation and IQ 70, with mental age 5–7 years, yet fit to testify.
- AAA’s direct testimony at age 20: she identified Allan as XXX’s father, recounted four occasions of non-consensual sex at age 13, and noted payments received.
- Defense Evidence
- Allan and his daughter testified, and Allan denied the charges, alleging fabrication by AAA’s father for personal vendetta.
- DNA paternity test: biological samples were collected in open court; Forensic Biologist Dela Cruz testified to a complete match at 15 loci, yielding 99.9999% probability that Allan is the father of AAA’s child.
- Lower Courts’ Decisions
- The RTC convicted Allan of four counts of simple rape (March 29, 2011), emphasizing AAA’s credible testimony, medical findings, and DNA results.
- The CA affirmed (Nov. 9, 2012), holding that force need not be proven when the victim is intellectually disabled and that AAA’s testimony was categorical and supported by corroborative evidence.
Issues:
- Whether the prosecution proved beyond reasonable doubt that Allan committed four counts of rape against AAA, an intellectually disabled person, given the alleged inconsistencies in AAA’s testimony and challenges to the DNA paternity test.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)