G.R. No. 229508, March 24, 2021
People of the Philippines, Plaintiff-Appellee, vs. Dennis Paul Toledo y Buriga, Accused-Appellant.

FACTS

Accused-appellant Dennis Paul Toledo y Buriga was charged with rape in relation to Republic Act No. 7610 for allegedly having sexual intercourse with the victim, AAA, an 8-year-old minor, on April 11, 2004, in Quezon City. The prosecution presented testimonies establishing that on said date, AAA and her younger brother BBB were playing when Toledo invited them to his house, promising money, food, and computer use. At his residence, Toledo isolated AAA, undressed her, and inserted his penis and finger into her vagina twice, threatening to harm her and her brother if she shouted. Afterward, AAA and BBB were given fare money and left. AAA’s parents discovered the incident after noticing blood on her towel and upon examination of her person. A medico-legal examination confirmed recent loss of virginity. Toledo was later identified and apprehended based on AAA’s description of him as a cripple with crutches. Toledo’s defense was insanity. He underwent mental examinations by the National Center for Mental Health (NCMH), which initially found him incompetent to stand trial due to schizophrenia. After years of archival, a subsequent NCMH report found him fit for trial. The defense presented NCMH personnel who testified that Toledo suffered from schizophrenia but could only state the possibility that this condition existed at the time of the crime’s commission.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of accused-appellant for rape in relation to R.A. No. 7610, despite his claim of insanity as a defense.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the prosecution successfully proved all elements of statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as the victim was under twelve years old, and the fact of carnal knowledge was established by AAA’s credible testimony and corroborating medico-legal findings. The defense of insanity was not sufficiently proven. The defense witnesses could only attest to the possibility that Toledo was suffering from schizophrenia at the time of the crime, not its actual existence. Insanity must be proven as a fact, with clear evidence of complete deprivation of intelligence or discernment at the very moment of the crime’s commission. Mere possibility is insufficient to overcome the presumption of sanity. The trial court’s assessment of AAA’s testimony as candid, straightforward, and detailed was accorded finality. The penalty of reclusion perpetua without eligibility for parole and the awarded damages were affirmed.