G.R. No. 177756 , March 3, 2008
People of the Philippines, plaintiff-appellee, vs. Salvador Nieto y Cabalse @ “Ador”, accused-appellant.

FACTS

The accused-appellant, Salvador Nieto, was charged with two counts of rape under Article 335 of the Revised Penal Code, as amended. The victim, AAA, was a 24-year-old woman diagnosed as a mental retardate with a mental age of five years and three months. The prosecution alleged that Nieto, a neighbor, raped AAA on December 30, 1999, and again on January 3, 2000, in their barangay in Pangasinan. AAA testified that on both occasions, Nieto entered her grandmother’s house when she was alone, used force to bring her to a nearby farmland or to compel her inside the house, undressed her, and had carnal knowledge against her will. The incidents were later reported to the police by AAA’s relatives.
The defense presented a different version, claiming denial and alibi. Nieto asserted he was elsewhere during the alleged incidents. He also attempted to impeach AAA’s credibility by highlighting her admission during cross-examination that she had been raped five times previously by another man in a different province. The trial court convicted Nieto of two counts of simple rape, a ruling affirmed by the Court of Appeals. The case was elevated to the Supreme Court via automatic review.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the principles governing rape cases, emphasizing that the credibility of the complainant is paramount. It found AAA’s testimony to be straightforward, consistent, and credible. The Court dismissed the defense’s attempt to undermine her credibility based on her past victimization, ruling that a prior rape does not make a victim less credible or less deserving of justice; it is irrelevant to the charges against the present accused. The Court also noted that her mental condition, as established by the psychologist’s testimony, made her incapable of fabricating a detailed story of sexual abuse.
The legal logic centered on the statutory definition of rape under Article 266-A. The Court clarified that while the Informations alleged the use of “force,” the conviction was properly based on the circumstance that the victim was “deprived of reason.” A mental retardate with the mental capacity of a five-year-old is legally considered deprived of reason, incapable of giving intelligent consent to sexual acts. Therefore, carnal knowledge with such a victim constitutes rape regardless of the presence or absence of physical force. The medical findings of a healed hymenal laceration, consistent with penetration, corroborated AAA’s account. The defense of denial and alibi, unsubstantiated by clear and convincing evidence, could not prevail over the positive identification and credible testimony of the victim. The penalties of reclusion perpetua for each count and the awards of civil indemnity, moral damages, and exemplary damages were sustained.