Case Summary (G.R. No. 212201)
Petitioner and Respondent
• Petitioner: People of the Philippines
• Respondent: Rodolfo Deniega y Espinosa
Key Dates
• May 2, 2007 – Incident occurred
• August 14, 2007 – Accused arraigned and pleaded not guilty
• November 15, 2011 – RTC of San Pedro, Laguna Decision convicting respondent
• September 27, 2013 – Court of Appeals Decision affirming conviction
• June 28, 2017 – Supreme Court Decision
Applicable Law
• 1987 Philippine Constitution
• Revised Penal Code, Art. 266-A(1)(d), as amended by RA 8353 (Anti-Rape Law of 1997)
• RA 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act)
• RA 9346 (Prohibiting the Death Penalty)
Factual Background
On the evening of May 2, 2007, AAA went with neighbors to a basketball game and returned home around 11 PM. Her mother noticed semen odor on AAA’s underwear. AAA then disclosed that Dodong had invited her to a nearby court, undressed her, and engaged in sexual intercourse. Barangay authorities, assisted by police, arrested an intoxicated Dodong the next morning. He admitted the act, professed love, and offered marriage; the offer was refused.
Procedural History
An amended information charged Dodong with statutory rape under Article 266-A(1)(d) RPC in relation to RA 7610, alleging the offended party’s mental disability. At trial, the prosecution presented AAA’s birth certificate and a psychiatric clinical abstract confirming moderate mental retardation (IQ 43). AAA and her mother testified, and medico-legal evidence revealed a deep healing laceration of the hymen. The RTC found the accused guilty beyond reasonable doubt, sentenced him to reclusion perpetua without eligibility for parole, and awarded civil indemnity (₱75,000), moral (₱75,000), and exemplary (₱30,000) damages. The Court of Appeals affirmed in toto.
Issue on Appeal
Whether the prosecution proved beyond reasonable doubt that accused had unlawful carnal knowledge of a mentally-retarded minor and whether the defenses of alibi and intoxication raised reasonable doubt.
Statutory Rape under Article 266-A(1)(d)
Under the 1987 Constitution and RPC Art. 266-A(1)(d), rape is committed when the offended party is under twelve years of age or is demented. Jurisprudence interprets “under twelve” to mean chronological age or mental age if intellectual disability is established. The law presumes incapacity to consent. A mental retardate with a mental age below twelve is protected under paragraph 1(d). Here, AAA’s mental age was six; accused knew of her condition. Proof of age and carnal knowledge suffice; force or threats are immaterial.
Credibility of the Victim
Both trial and appellate courts gave full credence to AAA’s straightforward and consistent testimony. Her cognitive impairment did not preclude her competence or credibility; in fact, her detailed account lent greater weight to her testimony. The testimony was corroborated by medical findings of hymenal laceration, yielding moral certainty of the crime.
Defense of Alibi and Intoxication
The Court reaffirmed that alibi is an inherently weak defense if unsupported by clear and convincing evidence. Accused failed to account for his whereabouts during the critical period (8–10 PM), a time window consistent with the commission of the rape. Proximity of the drinking session site to the crime scen
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Procedural History
- Criminal complaint for statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as amended by R.A. 8353, in relation to R.A. 7610, was filed in RTC Branch 31, San Pedro, Laguna (Criminal Case No. 6185-SPL).
- Accused-appellant Rodolfo Deniega y Espinosa pleaded not guilty at arraignment; he interposed denial and alibi defenses.
- On November 15, 2011, the RTC found him guilty beyond reasonable doubt, sentenced him to reclusion perpetua without eligibility for parole, and awarded civil indemnity (₱75,000), moral damages (₱75,000), and exemplary damages (₱30,000).
- The Court of Appeals, in CA-G.R. CR-H.C. No. 05348, affirmed the RTC decision in toto on September 27, 2013.
- Notice of Appeal to the Supreme Court was filed on October 10, 2013; the CA elevated records pursuant to its October 30, 2013 resolution.
- The Supreme Court gave parties opportunity to file supplemental briefs; both sides adopted their briefs before the CA as their supplemental briefs.
Facts
- AAA, a sixteen-year-old girl with moderate mental retardation and an IQ of 43 (mental age: six years), went to a basketball game on the evening of May 2, 2007.
- Upon returning home at around 11:00 p.m., her mother, BBB, discovered AAA’s pants wet and smelt semen on her underwear.
- AAA told her mother that “Dodong,” a known neighborhood delivery boy (accused-appellant), had invited her to another court, undressed her, lay her down, removed his own clothing, and inserted his penis into her vagina, making “up-and-down” movements.
- BBB preserved AAA’s underwear as evidence and reported the incident to barangay authorities; AAA underwent medical examination at Camp Vicente Lim, revealing a deep, healing hymenal laceration.
- Police and barangay officials arrested Deniega in a neighbor’s house while heavily intoxicated; after he sobered up, he admitted in front of his employer and BBB that he had sexual intercourse with AAA, professed love, and offered marriage to avoid charges.
- Prosecution established victim’s age and mental disability by Birth Certificate and clinical abstract of a psychiatrist; witnesses included the examining doctor and BBB.