G.R. No. 105556 . April 4, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO SAN JUAN, accused-appellant.

FACTS

The accused-appellant, Rodolfo San Juan, was convicted of rape by the Regional Trial Court of Valenzuela and sentenced to reclusion perpetua. The Information alleged that on September 30, 1988, he had carnal knowledge of Vivian Enriquez, a mentally retarded woman, through force, threats, and intimidation. The prosecution established that the victim’s father, Vicente Enriquez, witnessed the crime through a window of a vacant house, seeing the accused on top of his daughter with his penis inserted into her. The victim testified that the accused threatened to kill her family if she did not comply, removed her panty, and had sexual intercourse with her despite her pleas and physical resistance, which she could not sustain as she felt weak and her hands were held.
The defense presented a different narrative, claiming the sexual act was consensual. The accused testified that he and Vivian were sweethearts, that they had consensual sex on the date in question, and that her father discovered them and became angry. He asserted that the charge was fabricated due to the father’s anger over their relationship.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly in light of the victim’s mental condition and the conflicting claims of force versus consent.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony, corroborated by her father’s eyewitness account, remained unshaken. The trial court’s assessment of witness credibility is accorded high respect. The defense of a sweetheart relationship was rejected as a mere fabrication, unsupported by credible evidence and inconsistent with the victim’s mental state.
Critically, the Court ruled that even assuming the victim did not offer tenacious physical resistance, her mental retardation was a pivotal factor. A mental retardate is legally incapable of giving intelligent consent to a sexual act. The law presumes coercion when the victim suffers from mental abnormality or deficiency. Therefore, carnal knowledge of such a person constitutes rape under Article 335 of the Revised Penal Code, as the element of consent is legally absent. The accused’s knowledge of her condition was evident from their proximity as neighbors. The Court modified the award of civil indemnity, increasing it to Fifty Thousand Pesos (P50,000.00).