Case Summary (G.R. No. 170569)
Procedural History
The legal proceedings began with a formal complaint filed on November 2, 1995, wherein AAA accused appellant Norberto Mateo of rape by means of force and intimidation. The Regional Trial Court (RTC) of Pasig City found Mateo guilty of the crime and sentenced him to reclusion perpetua along with a requirement to indemnify AAA with P50,000. The decision was appealed to the Court of Appeals (CA), which affirmed the RTC's ruling with modifications.
Evidence and Testimonies
The prosecution's evidence indicated that AAA, a 16-year-old with only a grade one education, was at her sister's house when the incident occurred. Testimonies revealed that after drinking gin, Mateo lured AAA away, where he then forcibly removed her clothing and engaged in sexual intercourse with her. During this act, he threatened to kill her if she reported the incident. Witness Zenaida Torno, who was present at the scene, testified that she saw Mateo on top of AAA and attempted to intervene before reporting to the authorities.
Medical Examination Findings
AAA underwent a medical examination conducted by Dr. Reyes on the same day as the incident, which identified physical injuries on her body consistent with sexual assault, including a deep, fresh hymenal laceration. Dr. Reyes also noted AAA's mental deficiency through his observations and subsequent referral to a neuro-psychiatrist, who found her to have a mental age of 5 years and an IQ of 38.
Defense Arguments
Mateo denied the allegations, claiming that he and AAA were in a consensual relationship and that they were simply speaking at the time of the incident. He challenged the credibility of the eyewitness, arguing that the presence of other children during the act suggested consent and that AAA's failure to cry for help damaged her credibility.
Court of Appeals Decision
The CA upheld the RTC’s decision, affirming Mateo's conviction. It reasoned that the failure of AAA to scream or struggle was not determinative of consensuality, especially given the intimidation employed by Mateo. The CA underscored AAA's vulnerability as a minor and her mental capacity, reiterating that fear for personal safety can nullify any perceived consent.
Legal Standards and Constitution
The applicable law for the case was Article 335 of the Revised Penal Code, in force at the time of the offense, which defines rape as the carnal knowledge of a woman through force or intimidation. The ruling emphasized that the gravamen of the crime is the act of carnal knowledge against the victim's will.
Conclusion on Guilt
The CA contained that the prosecution sufficiently prov
...continue readingCase Syllabus (G.R. No. 170569)
Case Overview
- This case revolves around the appeal of Norberto Mateo y Dizon against a conviction for rape.
- The original decision was rendered by the Regional Trial Court (RTC) of Pasig City, which sentenced Mateo to reclusion perpetua.
- The Court of Appeals (CA) affirmed this decision but modified the civil liabilities.
Background of the Case
- AAA, the complainant, assisted by her father BBB, filed a complaint on November 2, 1995, charging Mateo with rape through force and intimidation.
- The complaint stated that the incident occurred on October 29, 1995, in Mandaluyong City.
- The accusatory portion of the complaint detailed the act of carnal knowledge against AAA's will, indicating the use of lewd design as well as force and intimidation.
Proceedings and Initial Ruling
- During the arraignment, Mateo pleaded not guilty.
- The RTC issued a decision on August 29, 1997, finding Mateo guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua, along with a P50,000.00 indemnity to the victim.
Appeal to the Court of Appeals
- Mateo initially appealed to the Supreme Court, which transferred the case to the CA.
- On September 30, 2005, the CA affirmed the RTC's decision but modified the ruling to include an additional P50,000.00 as moral damages.
Assignment of Errors by the Appellant
- Mateo raised two main errors:
- The RTC erred in finding his guilt proven beyond reasonable doubt.
- The RTC erroneously concluded that AAA was a mental retardate.