G.R. No. 95031 - People vs. Guerrero y Nares

The case involves the People of the Philippines as the plaintiff-appellee and Mario Guerrero y Nares as the accused-appellant.
The criminal complaint charged the accused with the crime of rape under Article 335 of the Revised Penal Code in relation to Article 63 (2).
The incident allegedly took place in or about July 1987 in the City of Manila.

Based on the complaint, the accused used force and intimidation to commit rape against Analiza Adana, a 16-year-old minor characterized as mentally deficient, illiterate, and physically vulnerable.
The accused allegedly forced the complainant into his residence (specifically, the nearby house of his daughter, Monique) by signaling her and then locking the door behind her.
Upon entry, he used a knife to threaten her by poking at her stomach and issued threats to kill both her and her family should she resist.
The accused removed Analiza’s clothing, forcibly brought her to a bedroom, and committed the act by mounting and forcibly inserting his penis while continuously employing intimidation.
After the act, he instructed Analiza to clean herself and leave the premises through the window.

On a subsequent occasion, several days later while Analiza was watching television, the accused again beckoned her from a nearby balcony.
Despite her initial refusal, he intercepted her path, forced her through the window into the house, and repeated the same pattern of threats, removal of clothing, and forced intercourse.
In both occurrences, despite being offered a ten peso (and later an additional twenty peso) bill, Analiza refused to consent but was compelled by threats of violence.

Analiza Adana’s testimony detailed her physical and mental condition: she was petite (about four feet tall), had a defective eye, was unschooled, and showed disorientation regarding time and personal details.
Testimonies from relatives, particularly her mother Hilda Adana, corroborated the victim's account, noting the absence of a menstrual period and later revelations of the assaults.
Witnesses, including family members and neighbors, presented consistent accounts, with Angela Guerrero and Rodrigo Cruz providing observations of suspicious interactions and a compromising situation at Monique’s house.
Medical evidence submitted by Dr. Marcial Cenido demonstrated physical findings (healed lacerations on the hymen, evidence of a non-virgin state) that were consistent with the history of sexual abuse.
The accused admitted to having carnal knowledge of Analiza but claimed that it was a result of a consensual “love affair” initiated by her, contending that she approached him for monetary favors.

The prosecution established that Analiza’s mental deficiency and physical vulnerability, compounded by the use of a knife and threats, negated any possibility of voluntary consent.
The defense argued that there existed a consensual relationship, citing previous encounters in which Analiza purportedly sought the accused and even willingly removed her clothing.
The trial record, however, indicated that her inability to intelligently consent was due both to her mental state and the force and intimidation employed by the accused.
The facts presented by the trial court highlighted her lack of capacity, noting her physical incapacities and mental immaturity as compelling circumstances that influenced her will.

The Regional Trial Court of Manila found the accused guilty of rape beyond reasonable doubt—even though the evidence showed two separate acts, the court sustained conviction for only one offense as charged in the information.
The judgment rendered reclusion perpetua against the accused, with an award of moral damages initially set at P12,000.00, later increased to P30,000.00 by the appellate court.
Additionally, the trial court ordered the accused to recognize the child potentially resulting from the crime, though this order was later modified based on legal rules concerning a married man's liability.

Whether the evidence established that Analiza Adana was mentally deficient to the extent that she was incapable of giving rational consent.
Whether the use of force, intimidation, and threats by the accused negated any defense of consensual intercourse despite her alleged previous contacts with him.
Whether the trial court correctly evaluated the credibility of the witness testimonies and the relevant medical evidence in concluding that the sexual acts were non-consensual.
Whether the accused-appellant’s allegations of a “love affair” sufficiently rebutted the factual findings of force and intimidation, or if they merely attempted to obscure the true nature of the crime.
Whether the trial court was correct in convicting the accused for one act of rape when two instances of sexual assault were purportedly committed.