G.R. No. 170569 - People vs. Mateo y Dizon

The complaint was filed on November 2, 1995, by AAA—assisted by her father, BBB—charging Norberto Mateo y Dizon with rape by means of force and intimidation.
The allegations stated that on October 29, 1995, in Mandaluyong City, the accused, with lewd design, used force and intimidation to have carnal knowledge of AAA against her will.

AAA, a 16-year-old barely literate and observed by others as having mental deficiencies, testified that the accused forcibly pulled her from a residential area to a grassy place.
Eyewitness testimony by Zenaida Torno, a local volunteer, corroborated the incident, stating that she saw the appellant engaged in the act and intervened by calling for help when she witnessed the act taking place in an open area with bystanders (including children).

Dr. Reyes, the medico-legal officer, conducted an examination on October 29, 1995, noting multiple linear abrasions on the victim’s back and thigh, and most significantly, a deep, fresh hymenal laceration at the 6:00 o’clock position which bled on slight pressure.
The physical findings supported the allegation of sexual penetration, even as they also suggested that the victim was possibly exposed to a rough surface during the incident.

The accused claimed that he had a consensual relationship with AAA, describing the encounter as an informal conversation that led to an alleged meeting at a school.
He argued that the absence of a struggle and the presence of bystanders indicated that the act was consensual, denying any force or threat during the encounter.

At trial (RTC, Pasig City, Branch 160), the accused was found guilty beyond reasonable doubt of rape and was sentenced to reclusion perpetua.
The RTC ruling emphasized the credibility of AAA’s testimony, noting her mental incapacity and inability to respond like a mature person under the circumstances.
The CA later affirmed the RTC decision with a modification, ordering the appellant to indemnify the complainant an amount of P50,000.00 as moral damages.
The records were eventually elevated to the Supreme Court upon the appellant filing his notice of appeal, wherein he raised two primary assignments of error:

Whether the totality of the evidence, including AAA’s testimony, eyewitness account by Torno, and the medico-legal report, sufficiently established that the accused committed rape beyond reasonable doubt.
Whether the absence of overt physical resistance or struggle from AAA affected the probative value of her testimony and the overall evidence against the appellant.

Whether the trial court’s observation and characterization of AAA as mentally deficient (or a mental retardate) was proper and supported by the evidence.
Whether the psychological factors and the reported mental age (as indicated by referrals for neuro-psychiatric examination) should impact the interpretation of her conduct during the incident.

Whether the appellant’s claim that the intercourse was consensual, based on their prior relationship and the absence of a struggle, holds merit when weighed against the threat to her life as testified by AAA.
Whether the presence of force and the threat (“I will kill you”) were sufficient to vitiate any appearance of consent.