G.R. No. 248997 . September 05, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDUARDO CERICOS, JR. Y OBIASCA A.K.A. “JR,” ACCUSED-APPELLANT.

FACTS

The case stemmed from five Informations charging accused-appellant Eduardo Cericos, Jr. with four counts of Rape and one count of Forcible Abduction with Rape. The victim, AAA, was a 15-year-old minor diagnosed with Intellectual Disability, having a mental age of a two-year-old. AAA met Cericos on social media and surreptitiously left her home to meet him in Tanay, Rizal, on August 18, 2016. Cericos then brought her to his house in Manila. There, he forcibly undressed and had carnal knowledge of her despite her resistance, which constituted the charge of Forcible Abduction with Rape. Later that evening, and again on the morning and midday of August 19, Cericos raped AAA multiple times. On August 20, after a drinking session, Cericos again sexually assaulted the inebriated AAA.
AAA was eventually recovered by her guardian and sister after they contacted Cericos through social media. At the barangay hall, AAA identified Cericos as her rapist. A medico-legal examination revealed findings consistent with blunt force or penetrating trauma. The Regional Trial Court convicted Cericos of four counts of Rape but acquitted him of Forcible Abduction with Rape, finding that the element of taking the victim away was not proven, as AAA went with him voluntarily. The Court of Appeals affirmed the RTC decision in toto.

ISSUE

The core issue is whether the guilt of accused-appellant Eduardo Cericos, Jr. for the four counts of Rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the elements of rape under Article 266-A of the Revised Penal Code. It found that the prosecution successfully established all elements: (1) Cericos had carnal knowledge of AAA; (2) he accomplished this through force, threat, or intimidation; and (3) AAA was under 18 years of age at the time. The Court gave full credence to AAA’s categorical, consistent, and straightforward testimony detailing the successive sexual assaults. Her testimony was corroborated by the medico-legal findings of genital trauma.
The Court emphasized that AAA’s intellectual disability, with a mental age of two, rendered her incapable of giving intelligent consent to any sexual act. This condition made her exceptionally vulnerable and incapable of resistance in a manner expected of a normal adult. Her failure to shout or escape immediately did not negate the presence of force and intimidation, as the law accounts for the victim’s state of mind and the overwhelming influence of the accused. The defense of a sweetheart relationship was rejected, as even if one existed, it does not justify rape, especially given the victim’s profound mental incapacity. The Court modified the awards of damages in accordance with prevailing jurisprudence, ordering civil indemnity, moral damages, and exemplary damages for each count of rape.