G.R. No. 172069 ; January 30, 2008
PEOPLE OF THE PHILIPPINES, appellee, vs. MARIO S. MARTIN, appellant.

FACTS

The appellant, Mario S. Martin, was charged with the rape of his ten-year-old daughter, AAA, a child diagnosed with Down Syndrome and moderate mental retardation. The prosecution established that on or about January 5, 1999, in San Juan, Metro Manila, AAA was brought to her father’s house. Later that night, her mother noticed her scratching her private parts. Upon inquiry, AAA revealed that her father had inserted his penis into her vagina and mouth, taped her mouth to prevent her from making noise, and threatened to beat her if she told anyone. At trial, AAA testified in a simple and straightforward manner, stating that her father touched her breasts, removed her panty, and inserted his “tete” into her vagina, which caused her pain. She indicated this happened five times.
The medico-legal officer, Dr. James Belgira, confirmed a deep, healed hymenal laceration consistent with penetration by a hard, blunt object. A court-directed psychological evaluation by the DSWD psychiatrist diagnosed AAA with Down Syndrome, having an IQ of 41.8, a mental age of 4.6 years, and a social age of 7 years. The defense consisted of a denial, with the appellant claiming the accusation was fabricated by his estranged wife and asserting that the crowded conditions of his home made the crime impossible. His son corroborated this alibi.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt, considering the mental condition of the victim and the defense of denial and alibi.

RULING

The Supreme Court affirmed the appellant’s conviction. The Court emphasized that the testimony of a mentally retarded rape victim, when credible and consistent, is accorded full weight and credit. AAA’s testimony, though delivered with childlike simplicity, was clear, candid, and unwavering on the central fact of sexual violation by her father. Her mental deficiency, far from diminishing her credibility, made it improbable for her to fabricate a coherent story of such a complex and degrading experience. The Court found her account inherently believable and consistent with the physical findings of the medico-legal expert.
The defense of denial and alibi was rejected as inherently weak and insufficient to overcome the positive identification and categorical testimony of the victim. Alibi must be supported by clear and convincing evidence of the physical impossibility of the accused being at the crime scene, which the defense failed to establish. The appellant’s relationship to AAA as her father and moral ascendancy supplied the intimidation necessary to constitute rape, rendering physical force unnecessary. The qualifying circumstances of minority and mental disability were duly proven, warranting the imposition of the supreme penalty. However, pursuant to Republic Act No. 9346 , the death penalty was automatically reduced to reclusion perpetua without eligibility for parole.