G.R. No. 225729 , March 11, 2020
People of the Philippines, Plaintiff-Appellee, vs. Valentino Catig y Genteroni, Accused-Appellant.

FACTS

An Information dated July 24, 2008, charged appellant Valentino Catig y Genteroni with the rape of AAA, a 15-year-old minor who is mentally retarded, on or about July 23, 2008, in Zambales. The prosecution’s version established that on July 23, 2008, at around 9:30 a.m., AAA was asked by her sister BBB to fetch water from appellant’s house. Upon arrival, appellant instructed AAA to go inside his house, laid her on a bed, removed her shorts and panty, touched her vagina, and raped her. Afterward, appellant gave AAA money and sugarcane. When AAA returned home, BBB noticed bloodstains on her shorts worn backwards. AAA cried and narrated the rape. They immediately sought assistance from barangay authorities and the Municipal Social Welfare and Development Office. AAA was examined by Dr. Earl Yap, who found hymenal bleeding and laceration indicative of recent penetration. The defense presented appellant’s denial, claiming that on the day of the incident, AAA only came to his house looking for his daughter and asked for sugarcane. He noticed bloodstains on AAA’s hand and shorts. He alleged the accusation stemmed from his refusal to lend his bicycle and give his dog to BBB.

ISSUE

Whether the prosecution sufficiently established appellant’s guilt beyond reasonable doubt for the crime of rape.

RULING

Yes. The Supreme Court affirmed the findings of the lower courts with modifications. The Court held that the prosecution proved appellant’s guilt beyond reasonable doubt. The testimony of AAA, despite her mental handicap, was clear, categorical, and straightforward, detailing how she was raped inside appellant’s house. Her credibility was upheld, as the trial court had the best opportunity to observe her demeanor. Her testimony was corroborated by the medical findings of hymenal laceration and bleeding. The Court agreed with the Court of Appeals that appellant is guilty of Simple Rape under Article 266-A(1)(b) of the Revised Penal Code, as AAA, being mentally deficient, is considered a person “deprived of reason,” not “demented” under paragraph 1(d). The penalty of reclusion perpetua without eligibility for parole was affirmed. The Court modified the damages, ordering appellant to pay AAA P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with interest at 6% per annum from the finality of judgment until fully paid.