G.R. No. 126175 May 29, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO ROMUA, accused-appellant.

FACTS

The case involves the rape of Lolita Jaban, a 24-year-old mental retardate, on the evening of January 31, 1990, in Kabacan, Cotabato. The victim’s mother, Jovita Jaban, testified that she left Lolita at home while she watched a video at a neighbor’s house. The accused, Armando Romua, who was a relative living nearby, also attended but left early. Upon Jovita’s return home at around 9:30 PM, she encountered Romua inside her house, clad only in a brief and T-shirt, and about to leave. She found her daughter completely naked. Romua claimed he only entered because he heard a noise and saw the victim’s baby jumping on her. The following medical examination confirmed the presence of sperm in Lolita’s vaginal canal.
The prosecution established Lolita’s mental condition through the testimony of Dr. Crisostomo Necesario, who described her as mentally retarded and incapable of intelligible speech, and through her mother’s unchallenged account of her disability. The defense contested the conviction, arguing that the victim’s mental depravity was not sufficiently proven and that there was no direct identification of the accused by the victim herself.

ISSUE

The primary issue is whether the prosecution proved beyond reasonable doubt that Armando Romua raped Lolita Jaban, a person deprived of reason, despite the absence of the victim’s direct testimony.

RULING

The Supreme Court affirmed the conviction. The Court held that the victim’s mental depravity was conclusively established by the uncontroverted testimonies of the doctor and the victim’s mother, which described her as a mental retardate incapable of communication. This condition rendered her legally incapable of giving consent, satisfying the element of carnal knowledge with a woman deprived of reason under Article 335 of the Revised Penal Code.
Regarding the identification of the perpetrator, the Court ruled that direct testimony from the victim is not indispensable. Conviction can be sustained based on credible circumstantial evidence. The evidence presented—Romua’s presence alone inside the house at night, his state of undress, the victim’s nakedness, the immediate discovery and report, and the medical proof of recent sexual intercourse—collectively formed an unbroken chain leading to the inescapable conclusion that Romua was the perpetrator. His implausible explanation for his presence was rightly rejected by the trial court. The penalty was properly modified to reclusion perpetua, as the crime involved a person deprived of reason, warranting the single indivisible penalty prescribed by law. The Court also ordered an indemnity of Fifty Thousand Pesos (P50,000.00) to the victim.