G.R. No. 208406 February 29, 2016
PEOPLE OF THE PHILIPPINES, Appellee, vs. ALLAN RODRIGUEZ Y GRAJO, Appellant.

FACTS

The appellant, Allan Rodriguez, was charged with rape under Article 266-A of the Revised Penal Code for allegedly having carnal knowledge of AAA, a 27-year-old woman with mental retardation, on December 18, 2004. The prosecution established that AAA, while making rugs at her home, was called by the appellant, her neighbor, to look after his son. Upon entering his house, appellant closed the door, undressed her, and had sexual intercourse with her. AAA later reported the incident to her mother, BBB, using the word “ginalaw.” A medico-legal examination confirmed recent deep lacerations consistent with penile penetration. A neuro-psychiatric evaluation diagnosed AAA with severe mental retardation, having an IQ of 38 and a mental age of six years and two months.
The appellant denied the accusation, presenting an alibi that he was doing carpentry work elsewhere at the time. His wife corroborated this claim. The Regional Trial Court found him guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction, holding that AAA’s mental retardation was equivalent to the condition of “dementia” under the law, and that her credible testimony, supported by medical evidence, established the crime.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for rape, specifically concerning the sufficiency of evidence proving AAA’s mental state and the occurrence of the crime.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the application of Article 266-A(1)(d) of the Revised Penal Code, which defines rape as committed by a man who has carnal knowledge of a woman “who is demented.” The Court clarified that the term “demented” in this context is not limited to clinical dementia but encompasses any mental deficiency that renders the victim incapable of giving rational consent. The prosecution conclusively proved AAA’s severe mental retardation through the expert testimony of a psychologist and her evaluation report, which detailed her IQ of 38 and mental age of a six-year-old. This condition rendered her incapable of understanding the sexual act and giving valid consent.
The Court rejected the appellant’s arguments challenging AAA’s credibility and the evaluation’s adequacy. It ruled that AAA’s straightforward testimony, consistent with her mental capacity, was credible and untainted by improper coaching. Her account was corroborated by the medico-legal findings of recent vaginal lacerations. The defense of alibi was correctly dismissed as it could not prevail over AAA’s positive identification of the appellant as her assailant. Consequently, all elements of statutory rape under Article 266-A(1)(d) were proven beyond reasonable doubt: (1) sexual intercourse occurred, and (2) it was committed with a woman diagnosed as a mental retardate, which the law equates to being “demented” for the purpose of vitiating consent.