G.R. No. 234947 - People vs. Bermas y Asis

The case involves an appeal by Francisco Bermas y Asis, who was convicted of rape by the Regional Trial Court (RTC) and whose conviction was affirmed by the Court of Appeals (CA).
The Information charged Bermas with raping AAA, a mentally retarded individual, on January 10, 2008, using force and intimidation.
During the trial, the prosecution presented several witnesses, including AAA, her mother BBB, a physician, and a barangay captain, to establish the facts of the case.

BBB testified that AAA had been mentally retarded since birth, exhibiting behaviors such as hitting others and being unresponsive at times.
Barangay Captain CCC corroborated that he had known AAA for ten years and recognized her mental condition.
AAA recounted the events of the night of the incident, stating that Bermas and another man, Garry Padilla, forced her to engage in sexual acts.
Dr. Barasona examined AAA shortly after the incident and found evidence of penetration, noting her difficulty in understanding questions and suggesting a psychiatric evaluation.

Bermas provided a defense based on his testimony, claiming he was at a birthday party and did not engage in any sexual acts with AAA.
He stated that he was wrongfully accused after being seen with AAA by Barangay Captain CCC, who reported the incident to AAA's parents.

The RTC found Bermas guilty of rape, concluding that AAA's testimony, along with corroborating evidence from the barangay captain and the physician, established the crime.
The RTC sentenced Bermas to reclusion perpetua, emphasizing the victim's mental condition and the nature of the crime.

On appeal, Bermas contested the RTC's findings regarding AAA's mental retardation and the sufficiency of evidence for his conviction.
The CA upheld the RTC's decision, stating that the prosecution had proven the elements of rape, particularly that AAA was "deprived of reason" due to her mental condition.

The Supreme Court found merit in Bermas' appeal, ruling that the prosecution failed to prove all elements of the crime beyond a reasonable doubt.
The Court emphasized that the prosecution must establish both carnal knowledge and that the act was accomplished through force, intimidation, or when the victim was deprived of reason.

The Court noted that while mental retardation does not require complete deprivation of reason, it must be proven beyond reasonable doubt.
The testimonies presented by the prosecution were deemed insufficient to conclusively establish AAA's mental retardation.
The Court highlighted the need for clinical evidence or substantial corroboration to support claims of mental deficiency.