G.R. No. 93433 ; August 5, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NGUYEN DINH THAN, accused-appellant.

FACTS

The accused-appellant, Nguyen Dinh Than, was convicted of rape by the Regional Trial Court of Puerto Princesa City and sentenced to reclusion perpetua. The information alleged that on or about September 1, 1989, through force and intimidation and while armed with a knife, he had carnal knowledge of Tran Thi Thuc Doan, a 17-year-old mentally retarded Vietnamese refugee, against her will. The prosecution presented evidence that the victim, after massaging the intoxicated appellant, was sexually assaulted while others in the quarters slept. A medical examination the next day revealed fresh vaginal lacerations and the presence of spermatozoa. A psychological report indicated the complainant functioned in the lower mild retardation range, with a probable mental age of seven.
The defense presented a different account. The appellant denied the September 1 incident, claiming he was selling bread at the time. However, he admitted to having consensual sexual intercourse with the complainant on July 24, 1989. He also admitted knowing she was physically and mentally handicapped and acknowledged sending her a letter. On appeal, he assailed the psychological report as hearsay and argued that the victim was not completely deprived of reason as required under the Revised Penal Code.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt, particularly considering the mental state of the victim and the admissibility of evidence regarding her mental capacity.

RULING

The Supreme Court affirmed the conviction with modification as to indemnity. The Court found the appellant’s own judicial admission decisive. By admitting he had prior sexual intercourse with the complainant and, crucially, by admitting his knowledge of her mental handicap, the appellant effectively supplied the evidence of her mental condition. An admission, once made, is binding unless shown to be a palpable mistake, which was not demonstrated here. This admission rendered the challenge to the psychological report’s admissibility moot.
On the legal interpretation of “deprived of reason” under Article 335 of the Revised Penal Code, the Court held that complete deprivation of intelligence is not required. Citing established jurisprudence, the Court ruled that mental abnormality or deficiency is sufficient. The complainant’s obvious mental retardation, evidenced by her status as a ward requiring social services and the appellant’s own recognition of her condition, squarely placed her within the protective scope of the law. The Court found no ill motive for the mentally retarded refugee to fabricate such a serious charge. Therefore, the guilt of the appellant was proven beyond reasonable doubt.