G.R. No. 208648. April 13, 2016.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. REYNALDO UMANITO, ACCUSED-APPELLANT.

FACTS

Accused-appellant Reynaldo Umanito was charged with the rape of AAA, a mute and mentally retarded 19-year-old girl, sometime in March 2005 in Sultan Kudarat. AAA, testifying with the aid of an interpreter using sign language, identified Umanito as the person who raped and impregnated her. She demonstrated the act of sexual intercourse by tapping her thigh with two fingers. AAA’s mother, BBB, testified that she discovered AAA’s pregnancy in August 2005, and AAA gave birth to a baby boy in December 2005. When asked who impregnated her, AAA led BBB to Umanito’s house. A medical certificate confirmed AAA’s muteness, mental retardation, and pregnancy. Umanito denied the accusation, claiming he only learned of it when summoned by the barangay captain. The Regional Trial Court found Umanito guilty of rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the decision. Umanito appealed, arguing that AAA’s testimony was vague and insufficient to prove carnal knowledge, citing the case of People v. Guillermo.

ISSUE

Whether the testimony of the mentally retarded and mute victim, AAA, is credible and sufficient to prove beyond reasonable doubt that accused-appellant Reynaldo Umanito committed rape.

RULING

Yes. The Supreme Court affirmed the conviction. The lone testimony of a rape victim, if credible, is sufficient for conviction. Mental retardation does not automatically impair credibility; the acceptance of such testimony depends on the quality of the witness’s perceptions and ability to communicate them. The Court found AAA’s testimony credible, as she consistently identified Umanito as her rapist through sign language and gestures, which were interpreted in court. Her testimony was corroborated by her pregnancy and her act of leading her mother to Umanito’s house. The Court distinguished the cited case of People v. Guillermo, noting that here, AAA’s testimony was clear and consistent, and Umanito’s denial was uncorroborated. The crime committed is simple rape under Article 266-A(1)(b) of the Revised Penal Code, as a mentally deficient person is deemed incapable of giving consent. The penalty of reclusion perpetua was upheld. The Court modified the damages, ordering Umanito to pay an additional ₱30,000.00 as exemplary damages and interest at 6% per annum on all damages awarded from the finality of the judgment until fully paid.