Case Summary (G.R. No. 208013)
Charges and Trial Court Proceedings
Allan was charged with four counts of rape under Article 266-A, paragraph 1 of the Revised Penal Code as amended by R.A. 8353, for alleged sexual intercourse with AAA between October and December 2002 at Brgy. Puelay, Villasis, Pangasinan. He pleaded not guilty. The prosecution presented testimony from family members and experts, medico-legal findings of healed hymenal lacerations and pregnancy, neuropsychiatric evaluations confirming AAA’s intellectual disability, and AAA’s own testimony that Allan raped her on four occasions, resulting in pregnancy and the birth of her daughter XXX. The defense denied the charges, suggested fabrication by AAA’s father, and sought a DNA paternity test, which later established Allan as XXX’s biological father with 99.9999% probability. The trial court found AAA’s testimony credible, corroborated by medical evidence and DNA results, and convicted Allan of four counts of simple rape, imposing reclusion perpetua and P50,000 civil indemnity and moral damages per count.
Court of Appeals Decision
The Court of Appeals affirmed the conviction in toto. It held that rape of an intellectually disabled victim constitutes rape under Art. 266-A 1(d) irrespective of force or intimidation, and that AAA’s clear, categorical testimony sufficed to prove guilt beyond reasonable doubt. It further deemed the DNA evidence corroborative, though not essential, and upheld the trial court’s assessment of witness credibility.
Issue on Appeal
The sole issue before the Supreme Court was whether Allan’s guilt was proven beyond reasonable doubt. Allan challenged AAA’s credibility due to alleged inconsistencies concerning time, date, and place, and questioned the chain of custody and reliability of the DNA testing methodology.
Applicable Law
Article 266-A, paragraph 1(d) RPC (RA 8353): rape is committed when the offended party is under twelve years of age or is demented, even absent force or intimidation.
Rule 130, Sections 20–21, Rules of Court: competence of mentally retarded persons as witnesses depends on ability to perceive and relate facts.
Rule on DNA Evidence, Sections 7–9: criteria for assessing probative value, methodological reliability, and disputable presumption when probability of paternity ≥ 99.9%.
Supreme Court Ruling – Rape Elements
The Court held that rape requires proof of carnal knowledge of a “woman under circumstances” enumerated in Art. 266-A. Sexual congress with an intellectually disabled person is rape per paragraph 1(d) because such a victim cannot consent. AAA’s healed hymenal lacerations, positive pregnancy test, and delivery of a child constituted conclusive proof of carnal knowledge.
Supreme Court Ruling – Witness Credibility
The Court reaffirmed that intellectual disability does not automatically disqualify a witness. AAA’s coherent, straightforward, and consistent narration, combined with expert testimony on her high degree of honesty and inability to fabricate, rendered her t
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Facts of the Case
- Edgar Allan Corpuz y Flores (“Allan”) was charged with four counts of simple rape under Article 266-A, paragraph 1(d) of the Revised Penal Code, as amended by R.A. 8353.
- The victim, “AAA,” was 14 years old with a mental age of 5 years and 8 months (moderate mental retardation) at the time of the alleged rapes in 2002.
- The Informations alleged that Allan, by force, violence and intimidation, had sexual intercourse with AAA on four occasions, against her will and without her consent, within Villasis, Pangasinan.
- Upon arraignment, Allan pleaded not guilty and a joint trial on the merits proceeded before Branch 50, Regional Trial Court (RTC), Villasis, Pangasinan.
Procedural History
RTC, Branch 50 (Judge Manuel F. Pastor, Jr.) convicted Allan of four counts of simple rape, sentencing him to reclusion perpetua for each count and awarding P50,000 civil indemnity and P50,000 moral damages per count.
Court of Appeals (CA) affirmed the RTC Decision in CA-G.R. CR HC No. 04977 on November 9, 2012, finding:
- Carnal knowledge of an intellectually disabled person is rape under Art. 266-A(1).
- AAA’s testimony was credible and coherent.
- Prosecution evidence sufficed even without DNA results, though the DNA test corroborated paternity.
Allan appealed to the Supreme Court; the SC gave due course to his Notice of Appeal and required supplemental briefs. Both sides manifested no supplemental briefs.
Issue Presented
- Whether Allan’s guilt for four counts of simple rape was proven beyond reasonable doubt.
Victim’s Mental Capacity and Testimonial Competence
AAA underwent two neuropsychiatric examinations:
- February 26, 2003 (Brenda Tablizo, Psychologist II, NBI): IQ 42 (moderate mental retardation), mental age 5 years 8 months.
- Prior to testimony (Dr. Rachel Acosta): IQ 70 (mild mental retardation), mental age 5–7 years; fit to testify depending on emotional condition.
Under Rule 130, Rules of Court, an intellectually disabled person need only be able to perceive a