GR 197537; (July, 2013) (Digest)
G.R. No. 197537 ; July 24, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. NINOY ROSALES y ESTO, Accused-Appellant.
FACTS
The accused-appellant, Ninoy Rosales, was charged with the rape of AAA, a 39-year-old woman diagnosed with moderate mental retardation, having a mental age of six years and eight months. The prosecution alleged that on June 27, 2004, in Caloocan City, Rosales gave AAA money, forced her to his house, undressed her, and had sexual intercourse with her. AAA testified to the incident, and her mother reported it the following day. A medico-legal examination confirmed AAA was in a non-virgin state, with findings consistent with recent sexual activity. Rosales denied the rape, admitting AAA was at his house for a drinking session but claiming no knowledge of her mental condition.
ISSUE
Whether the trial court and the Court of Appeals erred in convicting the accused-appellant of rape based on the testimony of the mentally retarded victim and the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court held that the victim’s testimony, given her mental condition, was credible and straightforward. It rejected the appellant’s argument that the victim’s lack of outcry rendered her testimony incredible, emphasizing that a mentally retarded person cannot be judged by the behavioral standards of a normal individual. The Court cited jurisprudence stating that not every victim reacts uniformly to trauma. AAA’s clear and consistent identification of Rosales as her assailant, corroborated by the medico-legal findings and the psychological evaluation proving her mental disability, established the crime of rape under Article 266-A of the Revised Penal Code. The Court found the elements of sexual intercourse and the victim’s mental retardation, which rendered her incapable of giving consent, proven beyond reasonable doubt. The defense of denial was deemed weak and unsubstantiated. The penalty of reclusion perpetua was affirmed, and the awards for civil indemnity, moral damages, and exemplary damages were modified in line with prevailing jurisprudence.