Case Summary (G.R. No. 139471)
Background and Charges
On July 2, 1998, Rolando Magabo was charged with the crime of Rape under an Information alleging that he unlawfully and feloniously had carnal knowledge of Noemi Dacanay, using force and intimidation. The charge stemmed from an incident where Magabo allegedly undressed Noemi and forced her to engage in sexual intercourse against her will, with her being incapable of giving consent due to her mental condition.
Court Proceedings and Evidence
Initially assigned to Branch 103 of the Regional Trial Court of Quezon City, the case was reassigned to Branch 95 after Judge Jaime Salazar inhibited himself. Following the arraignment on October 1, 1998, where Magabo pleaded not guilty, trial proceedings commenced. The prosecution's evidence included testimony from Noemi, supported by a medical examination conducted by Dr. Ma. Christina Freyra, which revealed healed lacerations on Noemi’s hymen.
Defense Argument
In his defense, Magabo denied the rape, asserting that he was elsewhere at the time of the incident and suggesting a personal vendetta from a third party against him. He cast doubt on the mental retardation of Noemi as an essential element of the crime.
Trial Court's Findings
The trial court found overwhelming evidence establishing that Noemi, indeed, was a mental retardate and that the rape occurred. It was noted that Noemi's inability to provide coherent testimony further underscored her mental condition, corroborated by Dr. Freyra's observation. The conviction was rendered on May 14, 1999, sentencing Magabo to Reclusion Perpetua and requiring him to pay damages to the victim.
Appeal and Legal Standards
On appeal, Magabo argued that the prosecution failed to prove the elements of rape related to the victim's mental state, particularly that her mental capacity was equivalent to that of a child under twelve. However, the court clarified that proof of mental retardation was sufficient for establishing rape, as a mentally retarded individual is incapable of giving consent regardless of other force or intimidation factors.
Affirmation of Conviction
The appellate court upheld the trial court's findings, maintaining that the evidence presented was credible. It noted the establishe
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Case Overview
- This case involves an appeal by accused Rolando Magabo y Magarte from a decision rendered by the Regional Trial Court of Quezon City, Branch 95, on May 14, 1999.
- The court found Magabo guilty beyond reasonable doubt of the crime of Rape and sentenced him to suffer the penalty of Reclusion Perpetua.
Background of the Case
- On July 2, 1998, the accused was charged with the crime of Rape through an Information that described the offense occurring on June 23, 1998, against Noemi Dacanay, a mental retardate.
- The charge delineated the acts of force and intimidation used by the accused, including undressing the complainant and engaging in sexual intercourse against her will.
Procedural History
- The case was initially assigned to Branch 103 but was re-raffled to Branch 95 after the presiding judge, Jaime Salazar, voluntarily inhibited himself.
- The accused was arraigned on October 1, 1998, pleading not guilty.
- The trial proceeded with the prosecution presenting evidence against Magabo.
Prosecution's Evidence
- The prosecution established that on the day of the incident, Noemi Dacanay was selling fried bananas at the Frisco Market when she was approached by the accused, who invited her to his house.
- Once in the house, the accused began to kiss and fondle Noemi before having sexual intercourse with her.
- After the incident, Noemi reported the crime to her mother, who took her to the police.
- Medical examination by Dr. Ma. Christina Freyra confirmed healed lacerations and abrasions on Noemi's hymen, corroborating the sexua