G.R. No. 199402, November 12, 2014
People of the Philippines, Appellee, vs. Enrique Quintos y Badilla, Accused-appellant.

FACTS

Accused-appellant Enrique Quintos y Badilla was charged with two counts of rape against AAA, an intellectually disabled person (mental retardate) with a chronological age of 21 years but a mental age of 6 years and 2 months, and an IQ of 38, as established by the testimony of NBI clinical psychologist Brenda Tablizo. In Criminal Case No. 07-0873, he was accused of committing an act of sexual assault by inserting his penis into AAA’s mouth on or about October 25, 2007. In Criminal Case No. 07-0874, he was accused of having carnal knowledge with AAA when she was deprived of reason or otherwise unconscious or asleep on or about October 26, 2007. AAA testified that the accused, her neighbor, followed her into the bathroom, removed his clothing, and inserted his penis into her vagina on one occasion, and on another day, while she was sleeping, he laid on top of her and did the same. She also recalled an instance where he forced his penis into her mouth. A medico-legal report showed lacerations on her hymen. The accused denied the charges, claiming he was in a prior romantic and sexual relationship with AAA, and the charges were fabricated after he ended the relationship. The Regional Trial Court found him guilty of both counts of rape. The Court of Appeals affirmed the conviction with modification, adjusting the penalty in one case. The accused appealed to the Supreme Court.

ISSUE

Whether the accused is guilty beyond reasonable doubt of two counts of rape.

RULING

The Supreme Court affirmed the conviction. The Court held that the trial court and the Court of Appeals’ findings on the credibility of AAA’s testimony are entitled to great respect, as they had the opportunity to observe her demeanor. The intellectual disability of AAA does not make her testimony incredible, especially when corroborated by other evidence such as the medico-legal findings. A person with a mental age of a six-year-old child is incapable of fabricating a serious accusation like rape. The Court ruled that the elements of rape were present. For rape under Article 266-A(1) of the Revised Penal Code (Criminal Case No. 07-0874), carnal knowledge with a woman who is deprived of reason or otherwise unconscious was established. For rape by sexual assault under Article 266-A(2) (Criminal Case No. 07-0873), the act of inserting his penis into AAA’s mouth through force or intimidation was proven. The accused’s defenses of denial, alibi, and claim of a prior relationship were unsubstantiated and could not prevail over AAA’s positive identification and credible testimony. The awards of damages were sustained.