G.R. No. 203086 - People vs. Dalan y Paldingan

The case involves an appeal by Jose Dalan y Paldingan challenging the Court of Appeals (CA) decision dated January 31, 2012.
The CA had affirmed the judgment of the Regional Trial Court (RTC), Branch 64, Abatan, Buguias, Benguet, where the appellant was convicted beyond reasonable doubt of two counts of statutory rape.
The RTC’s judgment, rendered on December 3, 2009, found the appellant guilty for raping the victim, referred to as AAA, on two separate occasions (December 2006 and March 3, 2007).

AAA positively identified the appellant as the person who inserted his penis in her vagina during the two incidents.
Despite her moderate mental retardation, AAA was deemed capable of recalling and narrating the details of the sexual abuse.

Dr. Sabrina Florendo provided medical findings that corroborated the victim’s testimony.
The physical evidence noted a marked attenuated hymen at the 6 o’clock position and areas where the hymen was absent, supporting the evidence of repeated sexual intercourse.

Dr. Ekid administered a battery of tests to assess the mental age, social maturity, and emotional condition of AAA.
The tests confirmed that AAA, despite being chronologically older (17 years old at the time of the incident), had a mental age equivalent to that of a 4-year and 7-month old child.

The established fact of sexual intercourse between the appellant and the victim.
The demonstration that the victim’s mental retardation rendered her incapable of giving valid consent.

Affirming AAA’s consistent recollection of the incidents.
Ruling that the victim’s moderate mental retardation was sufficiently proven by the presented evidence.
Rejecting the appellant’s uncorroborated alibi, which claimed he was at a farm in Ca-ew, Bulalacao—a location only five minutes away from the crime scene.

The RTC had sentenced the appellant to reclusion perpetua.
The RTC ordered the payment of civil indemnity (P50,000.00) and moral damages (P50,000.00) for each count.
The CA’s decision maintained the conviction but set the stage for later modifications.

Whether the crime should be designated as statutory rape or simple rape when the victim suffers from moderate mental retardation.
The legal interpretation of mental retardation versus dementia in applying the provisions of Article 266-A of the Revised Penal Code.

The credibility and consistency of the victim’s testimony despite her mental condition.
The weight of the medical evidence provided by Dr. Florendo in affirming the occurrence of sexual abuse.

The role of expert testimony (Dr. Ekid) in establishing the mental age and condition of the victim.
How the expert findings influence the categorization of the sexual offense under the law.

Evaluation of the appellant’s uncorroborated alibi and its credibility.
The proximity of the alleged alibi location to the crime scene undermining the defense.