G.R. No. 141128 ; August 30, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ORPIANO DELOS SANTOS, accused-appellant.

FACTS

The accused, Orpiano Delos Santos, was charged with the rape of Rowena Caboteja, a 16-year-old minor and alleged retardate, in August 1995 in Baruan, Agno, Pangasinan. The information alleged he used force and intimidation, pulling her into a room, pointing a bolo at her neck, and having sexual intercourse against her will. He pleaded not guilty. The prosecution presented evidence that the victim, while seeking shelter from rain at the accused’s house, was pulled upstairs, gagged with her own shorts, and raped. She did not immediately report due to threats. Her parents later noticed her distress, and she revealed the rape. A medical examination revealed a healed hymenal laceration. A psychiatric evaluation diagnosed her with moderate mental retardation with psychosis, having a mental age of about seven years and an IQ of 47. The defense claimed they were sweethearts who had a consensual sexual relationship that ended when the victim’s mother objected. Defense witnesses, including the accused’s son, testified to this relationship and denied the victim was mentally retarded. The trial court convicted the accused of rape and sentenced him to reclusion perpetua, plus ordering him to indemnify the complainant P50,000.

ISSUE

1. Whether the trial court erred in finding Rowena Caboteja a mental retardate.
2. Assuming she was a mental retardate, whether the trial court erred in giving weight and credence to her testimony.
3. Whether the trial court erred in finding the guilt of the accused-appellant proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the trial court’s decision. On the first issue, the Court found no error in the trial court’s acceptance of the psychiatric evaluation diagnosing the victim with moderate mental retardation. The evaluation was conducted by a qualified expert over four sessions and included psychometric testing, which was sufficient. The defense’s claim that the process fell short of the standard in People vs. Cartuano, Jr. was unmeritorious, as the expert’s methodology was thorough. On the second issue, the Court held that the victim’s mental retardation did not disqualify her from testifying; her testimony was credible and consistent with medical findings. On the third issue, the Court found the victim’s testimony clear and convincing, establishing all elements of rape. The defense of a sweetheart relationship was rejected as inherently improbable and unsupported by credible evidence. The Court affirmed the penalty of reclusion perpetua and the award of P50,000 as civil indemnity, which was mandatory upon finding of rape.