G.R. No. 255740 - Pastor Corpus, Jr. y Belmoro vs. People

Case Summary (G.R. No. 255740)

Arraignment and Plea

At arraignment on October 14, 1996, the accused entered a plea of not guilty to both charges. The two cases were consolidated for a joint trial on the merits.

Psychiatric Examination and Competency of the Complainant

When Jonalyn first testified, the prosecution moved for a psychiatric examination to determine her capacity to testify. Over defense objection, the trial court allowed initial direct examination. Observing her difficulty in expression, proceedings were suspended pending further assessment. Dr. Cecilia Tuazon then testified that Jonalyn suffered moderate mental retardation (mental age of eight) but understood the nature of the proceedings and could communicate her perceptions when prompted.

Trial Proceedings and Witness Testimony

Pursuant to Rule 132, Section 10(c), the court permitted leading questions for Jonalyn. She identified the accused, described being led to a house in Barangay Gatbuca, and testified that he twice had carnal knowledge of her without consent. Medico-legal evidence corroborated her testimony: Dr. Edgardo Gueco found fresh hymenal lacerations consistent with forcible defloration. Jonalyn’s aunt and other relatives testified regarding the filing of the complaint and incurred expenses.

Demurrer to Evidence and Defense Motions

After the prosecution rested, the defense demurred to the evidence on grounds that:
(a) The complaint was fatally defective, rendering the court without jurisdiction;
(b) Jonalyn lacked legal capacity both to initiate the action and to testify;
(c) Her testimony was coached and elicited through leading questions.
The trial court denied the demurrer. The accused then moved to submit the case without presenting evidence, and the court considered the case submitted for decision.

Trial Court Decision

On April 3, 1998, the Regional Trial Court convicted Bienvenido dela Cruz of rape in Case No. 1275-M-96 and acquitted him in No. 1274-M-96. It sentenced him to reclusion perpetua and awarded civil indemnity of ₱60,000.

Issues on Appeal

The appellant raised, among others, the following errors:

Lack of jurisdiction due to an allegedly defective complaint;
Incompetence of the mentally deficient complainant to file the complaint and to testify;
Improper use of leading questions;
Reliance on coached testimony; and
Inconsistency in acquittal on one docket and conviction on the other.

Government’s Response

The Office of the Solicitor General maintained that the complaint was validly filed by the offended party under Article 344, R.P.C., and Rule 110, Section 5, and that Jonalyn’s mental retardation did not render her incompetent. Her testimony was corroborated by medical evidence, and leading questions were permissible given her mental age.

Court’s Analysis on Jurisdiction

The Supreme Court held that the requirement in Article 344 to file a complaint initiates the proceeding but does not confer jurisdiction on the court. Since Jonalyn, as offended party, validly filed the complaint—even with assistance—the trial court properly acquired jurisdiction.

Competence of the Complainant as Witness

Under Rule 130, Section 20 of the Rules of Evidence, a witness is competent if capable of perceiving, recollecting, communicating, and understanding the obligation of an oath. The trial court’s finding—supported by expert testimony—that Jonalyn could communicate her perceptions warranted her competency despite mental retardation.

Credibili