Case Digest (G.R. No. 243988)
Facts:
The People of the Philippines v. XXX, G.R. No. 243988, August 27, 2020, the Supreme Court First Division, Lopez, J., writing for the Court. The plaintiff-appellee is The People of the Philippines; the accused-appellant is XXX.AAA, a 29‑year‑old woman with intellectual disability, and XXX were distant relatives and longtime neighbors. In November 2008 BBB (AAA’s mother) noticed AAA’s persistent sickness and vomiting; AAA then confessed she was pregnant and pointed to XXX as the father. BBB and AAA’s father confronted XXX at the barangay, where XXX expressed willingness to marry AAA and promised to support the child, but the marriage did not materialize; AAA later gave birth to a daughter.
On April 13, 2013, AAA alleged that while pasturing a cow XXX dragged her into shrubs, removed her underwear, covered her mouth with clothes, and had sexual intercourse with her despite her resistance; she said XXX had threatened to kill her if she told her mother and later disclosed that she had had sex with XXX on several occasions. XXX admitted sexual intercourse in November 2008, claimed they were lovers and that he financially supported the child, but denied any sexual encounter on April 13, 2013; he also disputed that AAA was mentally retarded. XXX’s mother testified that they had a romantic relationship.
XXX was charged in two informations: Criminal Case No. CBU‑101439 (Rape, alleged November 2008) under Article 266‑A, paragraph 1(d) of the Revised Penal Code as amended by RA No. 8353, and Criminal Case No. CBU‑101440 (sexual abuse under RA No. 7610) for the April 13, 2013 incident. At trial the prosecution presented BBB and a psychologist who administered the TONI‑3 test; the psychologist testified AAA’s chronological age was 29 but her mental age was comparable to a six‑year‑old with a very poor IQ and severe reduction in emotional expressiveness, and that she could be easily lured or threatened. The trial judge observed AAA’s demeanor and credited the psychologist’s findings.
On July 4, 2016, the Regional Trial Court convicted XXX of Rape in Criminal Case No. CBU‑101439 and sentenced him to reclusion perpetua, ordering damages; the trial court acquitted him of RA 7610 in Criminal Case No. CBU‑101440. XXX appealed to the Court of Appeals (CA) in CA‑G.R. CR‑HC No. 02447, arguing the intercourse was consensual ("sweetheart" theory) and that AAA was not mentally retarded. On June 29, 20...(Pro-only)
Issues:
- Did the prosecution prove beyond reasonable doubt the elements of statutory rape under Article 266‑A(1)(d) — i.e., that the offended party had a mental age below twelve and that the accused had carnal knowledge?
- Did the prosecution prove the qualifying circumstance that the accused knew of the victim’s mental disability at the time of the offense so as to elevat...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)