G.R. No. 247976 , May 14, 2021
People of the Philippines, Plaintiff-Appellee, vs. Edilberto Manuel, Jr. y Mangalindan, Accused-Appellant.

FACTS

Accused-appellant Edilberto Manuel, Jr. was charged with rape for having carnal knowledge of AAA, a 15-year-old female minor deprived of reason, sometime in January 2013. The information alleged that the offender knew of the mental retardation of the complainant. AAA, born on March 11, 1997, was diagnosed with mental retardation, having a developmental age of 5 to 5.5 years old at age 16. She was under the care of her aunt, BBB. Accused-appellant is the live-in partner of AAA’s biological mother, CCC. AAA testified that accused-appellant, whom she referred to as “Kuya Boy” or “Charles,” touched her vagina, inserted his penis, and kissed her. She stated this happened repeatedly, and she did not report it due to threats. BBB learned of a suspicious incident from a helper and, upon inquiry, AAA disclosed that accused-appellant inserted his finger into her private part. This led to a barangay report and a medical examination. Dr. Camarillo testified that the medico-legal report showed no evident ana-genital injury but clarified this does not exclude sexual abuse. Dr. Lazaro, a Developmental and Behavioral Pediatrician, testified on AAA’s mental condition. The defense presented accused-appellant and CCC, who denied the accusations, claiming they were fabricated due to family disapproval of their relationship and that accused-appellant was always at their store. The Regional Trial Court (RTC) found accused-appellant guilty of rape under Article 266-A of the Revised Penal Code and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral, and exemplary damages. The Court of Appeals (CA) affirmed the conviction but modified the damages and added that the penalty be without eligibility for parole.

ISSUE

Whether the lower courts erred in convicting accused-appellant of the crime charged.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications. The Court held that accused-appellant’s guilt for the generic crime of rape was proven beyond reasonable doubt. The elements of rape under Article 266-A(1)(d) of the Revised Penal Code were present: (1) the offender had carnal knowledge of the victim, and (2) the victim was demented at the time of the rape. AAA’s credible and consistent testimony, despite her mental deficiency, positively identified accused-appellant as her abuser. The absence of hymenal laceration is not indispensable for a rape conviction. The defense of denial and imputation of ill motive cannot prevail over the positive identification.
Furthermore, the Court found that the crime committed was Qualified Statutory Rape under Article 266-B, due to the allegation and proof that the accused knew of the victim’s mental retardation at the time of the offense. This qualifying circumstance warrants the imposition of the death penalty, but pursuant to Republic Act No. 9346 , the penalty is reduced to reclusion perpetua without eligibility for parole. The Court modified the awards to AAA: P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, all with legal interest at 6% per annum from the finality of judgment until fully paid.