G.R. No. L-47437 - People vs. Mariano y Obusan

Socorro Soria, a 24-year-old woman suffering from mental incapacity (demented/psychotic), had been confined at the National Mental Hospital in Mandaluyong, Manila, from February 26, 1971, to May 3, 1974, and was later transferred for further treatment at the Don Susano J. Rodriguez Memorial Hospital in Pili, Camarines Sur.
On May 26, 1975, her parents brought her home to Burabod, Daet, Camarines Norte, where she was to be treated by Gamelo Mariano y Obusan, the appellant, known locally as a faith healer or “spiritista.”

On the afternoon of September 25, 1976, the appellant went to the Soria residence to treat Socorro. After obtaining “salonpas” from Mrs. Maria Soria, the victim’s mother, he entered Socorro’s room and locked the door.
Mrs. Soria, while attending to her customers at a nearby rice mill, was alerted by her daughter-in-law, Elizabeth Albino Soria, that the door remained locked. Upon approaching and peering through a small aperture, both women witnessed the appellant engaged in sexual intercourse with a naked Socorro (naked from the waist down).
In the course of the intrusion, Mrs. Soria climbed atop a cabinet to get a better view and even grabbed the appellant’s hair, prompting him to abruptly stand up with his penis still erect. He hastily tried to escape but was intercepted by Elizabeth.

Socorro was immediately taken to the Camarines Norte Provincial Hospital, where Dra. Amelia Paguirigan conducted an examination.
The physician noted:

These physical signs, particularly the lacerations of the hymen, were deemed indubitable proof of penetration.

The appellant denied ever having had any sexual intercourse with Socorro, stating that he had only been treating her since July 1976.
He claimed that:

One week prior to the incident, he had informed Mrs. Soria that Socorro’s mental illness was beyond his capacity to cure and recommended another faith healer.
On the day of the incident, he was summoned by Mrs. Soria’s nephew and, after obtaining permission from Socorro’s mother, entered her room solely to perform the treatment before immediately leaving afterward.

On September 27, 1976, a verified complaint for rape, signed by Mrs. Maria Soria, was filed, leading to an information being filed before the Court of First Instance of Camarines Norte.
The trial court found the evidence “overwhelming” based on the credible testimony of the victim’s mother and corroborative physical findings by the examining physician.

The appellant argued that the trial court lacked jurisdiction because the rape complaint was not filed by the victim herself or, if by a parent, that the mother did not have the authority to file it since the father was still living.
He relied on the provisions of Rule 110 of the Rules of Court and Article 344 of the Revised Penal Code regarding the exclusive right to file complaints for crimes such as rape.

Whether the evidentiary records, including the testimony of Mrs. Soria and the physical findings by the examining physician, are sufficient to establish that the appellant committed the crime of rape.

Was the locked door and witnessing of the act by Mrs. Soria sufficient to prove the sexual intercourse occurred?
Do the physical injuries (hymenal tears at specific positions and abrasions) conclusively establish penetration?

Whether the appellant’s defense that he merely treated the victim and that his entry was conducted with permission is credible in light of the evidence and circumstances.

Whether the complaint filed by the victim’s mother was procedurally valid under Rule 110 and Article 344 of the Revised Penal Code, despite the fact that the victim’s father was still living.

Can a complaint for rape be filed solely by the mother without requiring the father’s involvement?
Does the joint parental authority principle impact the jurisdiction of the court in such cases?