Case Summary (G.R. No. L-47437)
Factual Background
Socorro, aged 24 at the time of the incident, had been confined in a mental institution since 1971 due to her psychological issues. In May 1975, her parents brought her home for treatment by Gamelo, who was known locally as a faith healer. On September 25, 1976, while treating Socorro, Gamelo locked the door to her room. When the victim’s mother checked after being alerted about the locked door, she discovered Gamelo in the act of sexual intercourse with Socorro.
Evidence of the Crime
Upon Mrs. Soria’s intervention, Gamelo attempted to flee but was confronted. Following the incident, Socorro was examined by Dra. Amelia Paguirigan, who reported clear signs of sexual assault, including abrasions and hymenal tears, corroborating the victim's mother's claims. The medical findings indicated significant physical evidence consistent with the commission of rape.
Defense of the Accused
Gamelo denied the charges, claiming that he had not engaged in any sexual conduct with Socorro. He argued that he had advised the Soria family to seek a different healer due to the severity of Socorro's condition. He contended that he was permitted by Mrs. Soria to enter Socorro's room solely for therapeutic purposes.
Jurisdictional Challenges
Gamelo disputed the jurisdiction of the trial court, asserting that the complaint filed by Socorro's mother was invalid because her father was still alive. He referenced Rule 110 of the Rules of Court, which stipulates who may prosecute cases of seduction, abduction, and rape. However, the court clarified that while parents share authority over their children, the mother could file a complaint in the absence of the father's action. The existing precedent allowed for the mother's complaint to confer jurisdiction upon the court despite the father's passive role.
Legal Principles Applied
The court found overwhelming evidence supporting the accusation against Gamelo. It reiterated that sexual intercourse with a mentally incapacitated individual constitutes rape, acknowledging that individuals in such a state are incapable of giving rational consent. The definitive conclusions drawn fr
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Case Information
- Court: Second Division
- G.R. No.: L-47437
- Decision Date: September 29, 1983
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Gamelo Mariano y Obusan
Case Background
- The case arises from a decision of the Court of First Instance of Camarines Norte.
- Gamelo Mariano y Obusan was found guilty of the crime of rape against Socorro Soria, a mentally ill woman.
- The sentence imposed was reclusion perpetua, moral damages of P12,000.00, and costs.
Facts of the Case
- Victim's Condition: Socorro Soria, 24 years old, was confined as a mental patient from February 26, 1971, to May 3, 1974, and subsequently received treatment from the appellant, a local faith healer.
- Incident Date: The alleged rape occurred on September 25, 1976.
- Actions of Appellant:
- Entered Socorro's room for treatment, locking the door behind him.
- Caught in the act of sexual intercourse by Mrs. Maria Soria, Socorro's mother, and her daughter-in-law, Elizabeth Albino Soria.
- Witness Observation:
- Mrs. Soria and Elizabeth observed the appellant on top of Socorro, who was partially undressed. Mrs. Soria intervened, leading to the appellant's hasty exit while attempting to explain his actions.
Medical Examination
- After the incident, Socorro was examined by Dr. Amelia Paguirigan, who noted:
- Abrasions on the labia majora.
- Hymenal tears at various positions indicating penetra