G.R. No. 226394 March 07, 2018
People of the Philippines, Plaintiff-Appellee, v. Raul Martinez and Lito Granada, Accused-Appellants.

FACTS

The accused-appellants, Raul Martinez and Lito Granada, were charged with the rape of AAA, a woman with mild mental retardation, on September 13, 2000, in Tudela, Cebu. The prosecution presented AAA’s testimony that Martinez dragged her from her home to a bushy area where Granada was waiting. Both men allegedly threatened her and her son, forced her to lie down, and took turns having sexual intercourse with her against her will. This account was corroborated by her young son, BBB. Medical and psychological evidence established that AAA, then 35 years old, had the mental capacity of a 7-year-old child. As a result of the incident, AAA became pregnant.
The defense interposed a denial and alleged the charge was fabricated due to a failed marriage proposal and extortion. Martinez claimed he and AAA were sweethearts and that their consensual sexual encounter on the same night led to the pregnancy. He asserted that AAA’s mother, CCC, implicated him and Granada in rape out of anger when he refused to marry AAA, though he offered child support. Granada denied any participation, claiming he merely witnessed Martinez and AAA together and was falsely implicated after he restrained CCC from attacking Martinez.

ISSUE

Whether the accused-appellants are guilty beyond reasonable doubt of the crime of rape under Article 266-A(1)(d) of the Revised Penal Code.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the legal principles governing rape committed against a person suffering from mental disability. Under Article 266-A(1)(d), rape is committed by having carnal knowledge of a woman “who is under the influence of any intoxicating, medici nal, narcotic, or other stupefying substance, or who is suffering from mental disability, which renders her incapable of giving her consent.” The prosecution conclusively proved AAA’s condition through expert testimony, showing she was incapable of giving intelligent consent to a sexual act.
The Court rejected the defense of a purported romantic relationship. The claim of a sweetheart defense was uncorroborated and inherently incredible. More critically, the law does not permit such a defense to exculpate an accused in cases involving a mental retardate. The victim’s mental disability negates the legal possibility of consent, regardless of any alleged relationship. The accused’s awareness or lack of awareness of the disability is immaterial; the offense is complete upon proof of carnal knowledge with a person proven to be mentally disabled. The Court found AAA’s testimony, supported by her son’s corroboration and the physical consequence of pregnancy, to be credible and consistent. The offer of child support was correctly viewed by the lower courts as an implied admission of paternity and conduct inconsistent with innocence. Accordingly, the Court upheld the penalty of reclusion perpetua for each appellant and affirmed the awarded damages.