GR 140209; (December, 2002) (Digest)
G.R. No. 140209 . December 27, 2002.
People of the Philippines, Plaintiff-Appellee, vs. Zainudin Dalandas, Accused-Appellant.
FACTS
An Information was filed charging Zainudin Dalandas with the rape of Junaida Dalanda, alleged to be mentally retarded, sometime in August 1994 in Pikit, Cotabato. The prosecution presented Junaida and her father, Budsal Dalanda. Junaida testified that the accused-appellant, her brother-in-law, forced her to have sexual intercourse by holding her hands and covering her mouth. She did not report the incident. Budsal testified that Junaida was 13 years old with a mental defect since childhood and that he learned of her pregnancy from his other daughter, Junaida’s sister. A medical examination confirmed Junaida was five to six months pregnant. The accused-appellant admitted to sexual intercourse but claimed it was consensual, alleging Junaida initiated the act and was not mentally retarded. He claimed the charge was filed because he failed to pay the “sala” or fine for impregnating her. The Regional Trial Court found accused-appellant guilty of qualified rape and imposed the death penalty.
ISSUE
Whether the prosecution proved beyond reasonable doubt that accused-appellant is guilty of qualified rape, specifically by proving that the victim was a mental retardate and that carnal knowledge was against her will.
RULING
The Supreme Court REVERSED and SET ASIDE the decision of the trial court and ACQUITTED accused-appellant. The prosecution failed to prove his guilt beyond reasonable doubt. The Court held that while mental retardation can be proven by means other than clinical evidence, such as testimony and observation, the evidence presented was insufficient. Junaida’s own testimony indicated she was in “normal condition” during the incident, knew how to read and write, and her narration of events was coherent and detailed. Her father’s testimony about her mental state was uncorroborated and insufficient. Furthermore, the Court found Junaida’s conduct after the alleged rape—failing to report it for months until her pregnancy became apparent—was contrary to the natural reaction of an outraged woman and cast doubt on the truthfulness of her claim of lack of consent. The prosecution thus failed to conclusively prove both that Junaida was a mental retardate and that the sexual intercourse was against her will.