G.R. No. 203041 ; June 5, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MOISES CAOILE, Accused-Appellant.

FACTS

Accused-appellant Moises Caoile was charged with two counts of Rape of a Demented Person under Article 266-A, paragraph 1(d) of the Revised Penal Code in two separate Amended Informations. The charges alleged that on or about April 6, 2005, and May 12, 2005, in Rosario, La Union, Caoile, knowing the mental disability of the victim, had sexual intercourse with AAA, a demented person with a mental age of seven years old, against her will. Caoile pleaded not guilty.
The prosecution presented AAA’s testimony detailing the incidents. She stated that Caoile, whom she called “uncle Moises,” invited her to a bamboo area, directed her to lie down, removed her clothing, and inserted his penis into her vagina, causing her pain. He gave her a red capsule afterward. A few days later, he invited her to gather guavas at a mountain and again had sexual intercourse with her. On another occasion, after inviting her to gather santol fruits, he again had carnal knowledge of her. AAA’s revelation came after hearing a friend complain that Caoile had mashed her breast.
Medical examinations were conducted. Dr. Claire Maramat found AAA had a multiple hymenal laceration, possibly inflicted weeks or months prior. Dr. Brenda Rosuman found spermatozoa in seminal fluid taken from AAA, indicating sexual intercourse. Psychologist Claire Baliaga and psychiatrist Dr. Roderico V. Ramos evaluated AAA, concluding she had moderate mental retardation with a mental age of a five to seven-year-old child.
The defense presented Caoile’s testimony, claiming AAA was his neighbor and frequent visitor, they developed a romantic relationship, and their sexual encounters were consensual. He claimed he did not know she was demented as she acted normally and finished elementary education. A defense-commissioned psychiatric evaluation by Dr. Lowell A. Rebucal concluded AAA had Mild Mental Retardation.
The Regional Trial Court (RTC) found Caoile guilty beyond reasonable doubt of two counts of rape and sentenced him to reclusion perpetua for each count, plus damages. The Court of Appeals affirmed the RTC decision with modifications to the damages. Caoile appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Moises Caoile for two counts of rape under Article 266-A, paragraph 1(d) of the Revised Penal Code.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATION regarding the award of damages. The Court held that all the elements of rape of a demented person were proven beyond reasonable doubt: (1) sexual intercourse occurred between the accused and the victim; (2) the act was accomplished through force, threat, or intimidation, or when the victim is deprived of reason or otherwise unconscious, or is under twelve years of age or is demented; and (3) the accused knew of the victim’s mental disability at the time of the commission of the crime.
The Court found AAA’s testimony credible, straightforward, and consistent. Her mental retardation did not impair her ability to give a coherent account of the traumatic events. The medical findings corroborated her testimony. The defense of a romantic relationship was rejected as inherently improbable and a mere denial. The Court ruled that the victim’s mental retardation, which rendered her incapable of giving rational consent, was sufficiently established by the prosecution’s expert witnesses. The accused’s knowledge of her condition was inferred from their proximity as neighbors and his interactions with her.
The awards of civil indemnity, moral damages, and exemplary damages were affirmed, with the amounts modified in accordance with prevailing jurisprudence.