GR 123096; (December, 2000) (Digest)
G.R. No. 123096 ; December 18, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO DUMANON y DUMANACAL and RICARDO LABRADOR y SUACILLO, accused-appellants.
FACTS
Accused-appellants Mario Dumanon and Ricardo Labrador were charged with the rape of Anacurita Anib. The initial complaint was filed by Anacurita’s mother, Dominga Anib, alleging that her daughter, a “retardate,” was raped at midnight on December 2, 1993. The Municipal Circuit Trial Court found probable cause, noting Anacurita’s apparent mental retardation. The case was forwarded, and an Information was filed bearing Anacurita’s thumbmark. During trial, the prosecution presented Anacurita, who testified that on the night in question, Ricardo first blocked her path, dragged her to a vacant house, and had carnal knowledge of her. After he left, Mario entered and similarly raped her. Her mother corroborated the events, stating she heard her daughter’s protests, found her disheveled, and was immediately told of the rape.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellants for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Anacurita’s credibility, finding her testimony on the sequential rape by both men to be clear, consistent, and credible. The defense’s attack on her mental capacity was unavailing; her retardation did not invalidate her testimony but was instead a factor considered in evaluating the force and intimidation used against her. The medical certificate confirming recent sexual intercourse and hymenal laceration provided physical corroboration. The Court also noted that the accused-appellants’ manifestation for a possible settlement of the case operated as an implied admission of guilt. Consequently, the penalty of reclusion perpetua was sustained. The civil awards were modified, increasing moral damages to ₱50,000 and granting an additional ₱50,000 as civil indemnity, in line with prevailing jurisprudence.