G.R. No. 246948 . July 05, 2021.
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. REYNALDO GABATBAT Y BALBOA, ACCUSED-APPELLANT.

FACTS

On January 20, 2011, in Quezon City, accused-appellant Reynaldo Gabatbat, a friend of the victim’s father, chased the 14-year-old victim AAA inside a vacant lot. He caught her, punched her thighs, dragged her to a hut, laid her down, removed her shorts and panty and his own pants, and inserted his penis into her vagina while pointing a knife at her neck, despite her resistance. He threatened to kill her parents and siblings if she told anyone. AAA revealed the incident to her mother BBB two months later. A medico-legal examination revealed a healed hymenal laceration and evidence of previous blunt force or penetrating genital trauma. An Information was filed charging Gabatbat with Statutory Rape under Article 266-B(10) of the Revised Penal Code, alleging the victim was a minor suffering from mental disability. During trial, the prosecution presented AAA, BBB, and Dr. Palmero, while the defense presented only Gabatbat, who denied the accusation and claimed he was delivering vegetables at the time. The Regional Trial Court convicted Gabatbat of simple rape under Article 266-A(1)(b), finding the qualifying circumstance of knowledge of the victim’s intellectual disability not clearly proven. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

Whether accused-appellant is guilty of simple rape under Article 266-A, paragraph 1(b) of the Revised Penal Code, by having carnal knowledge of a woman who is allegedly a person with intellectual disability.

RULING

Yes. The Supreme Court affirmed the conviction for simple rape under Article 266-A(1)(b). The Court held that rape under this provision is committed when the offended party is “deprived of reason,” which includes those suffering from mental abnormality, deficiency, or intellectual disability. The victim’s intellectual disability was established through the consistent and credible testimonies of AAA and her mother BBB, detailing her condition and its manifestations, which constituted deprivation of reason. The defense of denial was unavailing against the positive identification and credible narration of the victim. The qualifying circumstance under Article 266-B(10) was not appreciated because the Information did not allege the offender’s knowledge of the mental disability, and such knowledge was not proven during trial. The Court modified the awards, ordering accused-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 legal interest from finality until fully paid. The penalty of reclusion perpetua was affirmed, with the qualification that the accused shall not be eligible for parole.