Case Digest (G.R. No. 243988)
Facts:
The case G.R. No. 243988 revolves around the accused, referred to as XXX, who was convicted of rape against AAA, a 29-year-old woman with mental disabilities. The events that transpired began in November 2008 when AAA's mother, BBB, noticed that her daughter was frequently feeling ill. Upon questioning AAA, she revealed her pregnancy and identified XXX as the father. Following this disclosure, BBB, along with AAA's father, confronted XXX in their barangay, where XXX expressed intention to marry AAA. However, due to the fierce anger of AAA's father, the marriage did not happen, although XXX committed to financially support the child.
On April 13, 2013, the situation escalated when XXX allegedly dragged AAA to a secluded area, removing her underwear and forcibly having sexual intercourse with her despite AAA's resistance. According to AAA, XXX had previously threatened to kill her if she told anyone about their sexual encounters, which had occurred multiple times
Case Digest (G.R. No. 243988)
Facts:
- Background and Relationship of the Parties
- AAA, a 29-year-old woman, and XXX were distant relatives and long-time neighbors.
- AAA became pregnant following an earlier episode in November 2008, when she confessed her pregnancy and identified XXX as the father.
- Prior to the pregnancy, BBB (AAA’s relative) and AAA’s father confronted XXX in the barangay after noticing AAA’s ill health and vomiting.
- The Incidents
- Incident in November 2008
- XXX admitted having sexual intercourse with AAA, who was described as having a mental age comparable to a six-year-old, despite her being 29 years old.
- The act was carried out “with lewd design,” using force and intimidation, taking advantage of AAA’s mental disability, and resulted in her becoming pregnant.
- The sexual act, being non-consensual due to AAA’s incapacity to give rational consent, formed the basis of the charge under Article 266-A, paragraph 1(d) of the Revised Penal Code (RPC).
- Incident on April 13, 2013
- While AAA was pasturing a cow, XXX suddenly dragged her into the shrubs and forcibly removed her underwear.
- He covered her mouth with cloth and proceeded to have sexual intercourse with her, despite AAA’s resistance which included hitting him with a piece of wood and a stone.
- This act was charged as sexual abuse under Section 5(b) of Republic Act (RA) No. 7610.
- Proceedings and Testimonial Evidence
- At trial, BBB testified regarding AAA’s status as mentally retarded and illiterate, while a psychologist confirmed that AAA’s mental age was that of a six-year-old, despite her chronological age of 29 years.
- XXX admitted to the sexual encounter in November 2008 but maintained that the intercourse was consensual under a “sweetheart” theory, supported by testimony from his own mother regarding a romantic relationship with AAA.
- XXX denied any sexual encounter on April 13, 2013, claiming he never approached AAA after being confronted in the barangay.
- The trial courts convicted XXX of rape for the November 2008 incident and acquitted him of the sexual abuse charge related to the April 2013 incident.
- Decisions and Appellate Review
- On July 4, 2016, the Regional Trial Court (RTC) convicted XXX of rape, sentencing him to reclusion perpetua and ordering him to pay various damages to AAA.
- XXX appealed the conviction, asserting that AAA consented to the sexual intercourse and denying that she was mentally retarded.
- The Court of Appeals (CA) affirmed the RTC’s findings, although it modified the award of damages, and dismissed the appeal on June 29, 2018.
Issues:
- Sufficiency of Evidence in Proving Statutory Rape
- Whether the prosecution proved that AAA, due to her mental disability, was incapable of giving rational consent despite her chronological age.
- Whether the psychological evidence establishing that AAA’s mental age was comparable to that of a six-year-old was sufficient to meet the statutory requirements for rape.
- Credibility and Relevance of the “Sweetheart” Theory
- Whether XXX’s assertion that he had a consensual “sweetheart” relationship with AAA was credible and supported by probative evidence.
- Whether the evidence presented could negate the presumption of incapacity to consent due to mental disability.
- Knowledge of the Victim’s Mental Disability
- Whether XXX had actual knowledge of AAA’s mental disability at the time of the incident, as required for the commission of qualified statutory rape.
- Whether the failure to sufficiently prove this element warrants a modification in the charge or penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)