G.R. No. 206419 . June 01, 2016
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RUBEN DELA ROSA, ACCUSED-APPELLANT.

FACTS

The accused, Ruben dela Rosa, was charged with Qualified Rape for allegedly having carnal knowledge of AAA, a 31-year-old woman with the mental age of a nine-year-old child, in June 2004 in Binangonan, Rizal. The prosecution established that dela Rosa and his family were living with AAA and her mother, BBB. BBB testified that she saw dela Rosa emerging from AAA’s room one evening. A neighbor later informed BBB that AAA had described, in her stunted language, acts of sexual abuse by “Daddy,” referring to dela Rosa. When confronted, AAA confirmed that dela Rosa had undressed her, kissed her breasts, and inserted his penis into her vagina. BBB promptly reported the incident, and a medical examination revealed physical signs consistent with sexual intercourse. A clinical psychologist from the National Center for Mental Health confirmed AAA’s mental retardation, diagnosing her with a mental age of nine.
The defense presented only dela Rosa, who interposed denial and alibi. He claimed his family no longer resided with AAA and BBB at the time of the alleged incident and suggested the complaint was fabricated in retaliation for a prior barangay case filed by his wife against BBB’s family. The Regional Trial Court found dela Rosa guilty beyond reasonable doubt of Qualified Rape under Article 266-A(1)(d) of the Revised Penal Code, as amended, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the awarded damages.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of Ruben dela Rosa for the crime of Qualified Rape.

RULING

Yes, the Supreme Court affirmed the conviction. The legal logic is anchored on the statutory definition of rape under Article 266-A(1)(d), which penalizes carnal knowledge with a woman who is “demented,” even absent force, threat, or intimidation. A mental retardate is legally incapable of giving consent to a sexual act. The prosecution successfully proved the two essential elements: sexual intercourse and the victim’s mental disability. AAA’s credible, spontaneous, and consistent testimony, corroborated by her mother and the psychologist’s findings, established the fact of rape. Her mental condition was conclusively proven by expert testimony, fulfilling the qualifying circumstance under Article 266-B that the offender knew of the victim’s mental disability.
The Court rejected the defense of denial and alibi as weak and unsubstantiated, especially when weighed against the positive identification by the victim. The alleged motive for fabrication was deemed insufficient to overturn the consistent factual findings of the lower courts. The Supreme Court modified the damages awarded, increasing civil indemnity, moral damages, and exemplary damages to ₱100,000.00 each, in accordance with prevailing jurisprudence, and imposed legal interest on all amounts until fully paid. The penalty of reclusion perpetua was affirmed, as the death penalty was prohibited at the time of the offense.