G.R. No. L-41819 February 28, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WINSTON MANLAPAZ y POLING, accused.

FACTS

The accused, Winston Manlapaz, a 19-year-old student, was charged with the rape of Therese Endencia, a 13-year-old girl. The prosecution established that the incidents occurred in Manlapaz’s apartment on November 28 and 30, 1972. The victim, Therese, was enrolled in a special school for the mentally retarded. Expert testimony from Dr. Fernando Hofileña, the school’s clinical head, confirmed that Therese had an unsound mind, with a mental age significantly below her chronological age, and was incapable of fully understanding the nature and consequences of sexual intercourse. The discovery of contraceptive pills in Therese’s possession on New Year’s Day 1973 led to her mother’s inquiry, wherein Therese revealed the sexual encounters. A medico-legal examination confirmed healed hymenal lacerations consistent with sexual intercourse more than a month prior.
At trial, Therese’s testimony regarding the use of force was incoherent and inconsistent due to her mental condition. The defense centered on Winston’s denial of sexual intercourse. The trial court convicted Winston Manlapaz of rape, sentencing him to reclusion perpetua. The case was elevated to the Supreme Court on automatic review.

ISSUE

The core issue is whether carnal knowledge of a mentally deficient minor, who is incapable of giving rational consent, constitutes rape under Article 335 of the Revised Penal Code, even in the absence of proven force or intimidation.

RULING

The Supreme Court affirmed the conviction. The legal logic is anchored on the interpretation of rape under Article 335, which includes carnal knowledge with a woman “deprived of reason or otherwise unconscious.” The Court clarified that “deprived of reason” does not require complete unconsciousness or total insanity; it encompasses mental deficiency or abnormality that renders the victim incapable of rational consent. The victim’s mental state is the determinative factor, not the presence of force or resistance.
Here, the unanimous expert and testimonial evidence established that Therese, due to her mental retardation, was deprived of reason. Consequently, she was legally incapable of giving valid consent to sexual intercourse. Her incoherent court narration was consistent with her diagnosed condition. Therefore, the accused’s carnal knowledge of her, which he admitted occurred on the dates in question, legally constituted rape by statutory definition. The absence of clear force became immaterial because the law presumes the act to be against her will given her incapacity. The penalty of reclusion perpetua was upheld, with a recommendation for executive clemency consideration due to the accused’s youth.