G.R. No. 207666 November 22, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. FLORIANO TAYABAN, Accused-appellant

FACTS

Accused-appellant Floriano Tayaban was charged with the rape of AAA, a 16-year-old with moderate mental retardation, in May 2008 in Lagawe, Ifugao. The prosecution established that AAA, who had been previously assessed with an intellectual disability, went to Tayaban’s house where he undressed her, had carnal knowledge multiple times, and bit her breast. A medical examination conducted about three months later revealed a healed hymenal laceration consistent with sexual intercourse. The defense presented an alibi, claiming Tayaban was in Baguio and later in Lamut during the alleged period, corroborated only by his wife.
The Regional Trial Court found Tayaban guilty beyond reasonable doubt of rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua without eligibility for parole. Tayaban appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for rape under Article 266-A of the Revised Penal Code.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction with modifications to the awards of damages. The Court held that all elements of rape under Article 266-A(1)(d) were proven beyond reasonable doubt. The provision punishes carnal knowledge with a woman who is “demented,” which jurisprudence interprets to include a victim with intellectual disability or mental retardation, as such a condition impairs her capacity to give rational consent. The victim’s mental age, not her chronological age, is determinative of this capacity.
The Court found the victim’s testimony credible and consistent. Her intellectual disability was sufficiently proven, and her straightforward narration of the sexual assault was corroborated by the medical finding of a healed hymenal laceration. The defense of alibi was rightly rejected for being weak and self-serving, especially since it was not physically impossible for the accused to have been at the crime scene. The positive identification by the victim prevails over an unsubstantiated alibi.
The penalty of reclusion perpetua without parole was correctly imposed pursuant to relevant laws. Following prevailing jurisprudence, the Court increased the awards to ₱100,000.00 each as civil indemnity, moral damages, and exemplary damages, all with legal interest.