G.R. No. 212201 - People vs. Deniega y EspiNo.

Accused-appellant Rodolfo Deniega y Espinosa appealed the Court of Appeals (CA) Decision dated September 27, 2013, which affirmed the Regional Trial Court (RTC) of San Pedro, Laguna’s November 15, 2011 Decision convicting him of statutory rape.
The RTC sentenced him to reclusion perpetua without eligibility for parole and ordered payment of ₱75,000 civil indemnity, ₱75,000 moral damages, and ₱30,000 exemplary damages.

The victim, AAA, was 16 years old chronologically but had moderate mental retardation with an IQ of 43, equivalent to a six-year-old mental age.
On May 2, 2007, AAA left home at around 7 p.m. to watch basketball. She returned at 11 p.m. with wet pants emitting a semen odor. Under questioning by her mother (BBB), she admitted that Deniega lured her to another basketball court, undressed her, lay on top of her, inserted his penis in her vagina, and made “up-and-down” movements.
BBB secured AAA’s underwear as evidence and reported the incident to barangay authorities. The barangay, assisted by police, arrested Deniega early the next morning after he sobered up. He admitted in their presence that he had intercourse with AAA, professed love, and offered marriage, which BBB rejected. AAA underwent a medical examination confirming a deep healing laceration of the hymen.

An Amended Information dated July 9, 2007 charged Deniega with statutory rape in violation of RA 7610 and Article 266-A(1)(d) of the Revised Penal Code (RPC). He pleaded not guilty upon arraignment on August 14, 2007.
Deniega’s defense consisted of a general denial and an alibi, claiming he spent May 2, 2007, from 8 a.m. to midnight painting, repairing an electric fan, and drinking with a friend.
After trial, the RTC found the prosecution proved beyond reasonable doubt the elements of statutory rape, credited AAA’s straightforward testimony, disbelieved the alibi, and convicted Deniega.
The CA affirmed in toto. Deniega then filed a Notice of Appeal to the Supreme Court, which gave due course on October 30, 2013. Both parties opted not to file supplemental briefs, adopting their CA submissions.

Whether the prosecution established beyond reasonable doubt the elements of statutory rape under Article 266-A(1)(d) of the RPC as amended.
Whether AAA’s mental retardation undermines her credibility as a witness.
Whether Deniega’s alibi and state of intoxication sufficiently negate his commission of the crime.
Whether the penalty and damage awards imposed by the RTC should be modified.