G.R. No. 188978; June 13, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARCIAL BAYRANTE Y BOAQUINA, Accused-Appellant.

FACTS

The accused-appellant, Marcial Bayrante, was charged with two counts of rape against his niece, AAA, a 20-year-old woman diagnosed with mild mental retardation, having a mental age of 9 to 10 years. The incidents allegedly occurred on the evening of February 19, 2002, in Pili, Camarines Sur. AAA testified that Bayrante brought her to a house, undressed her, and had carnal knowledge of her twice that night, using a knife to threaten her when she resisted. Her mother, BBB, reported that Bayrante, who was staying with their family, disappeared with AAA on February 14, 2002. They were found days later, after which AAA disclosed the rapes. Medical and psychiatric evaluations confirmed sexual abuse and AAA’s condition of post-traumatic stress disorder and mild mental retardation.
The Regional Trial Court convicted Bayrante of two counts of rape. The Court of Appeals affirmed the conviction but modified the penalty. Bayrante appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, specifically contesting the credibility of AAA’s testimony and the sufficiency of evidence for the charge of rape through sexual assault.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the credibility of AAA’s testimony, which was straightforward, consistent, and corroborated by medical findings and her mother’s testimony. The Court emphasized that the testimony of a mentally retarded victim, when credible, is given full weight. AAA’s detailed account of the two separate acts of sexual intercourse, including the pain she felt and the use of a knife, constituted clear proof of rape through carnal knowledge. The defense of denial and alibi presented by Bayrante was weak and uncorroborated. Regarding the legal sufficiency of the information, the Court ruled that while the informations alleged rape “by having carnal knowledge,” which technically describes rape under Article 266-A(1), the evidence also supported a finding of rape under Article 266-A(2) (sexual assault) due to AAA’s mental disability. However, since the accused was informed of the nature of the charge and was able to present a defense, and the evidence overwhelmingly proved sexual intercourse, any technical defect was cured. The Court found no reason to overturn the factual findings of the lower courts, which are accorded great respect. The penalties and damages awarded by the Court of Appeals were sustained.