GR 95031; (March, 1995) (Digest)
G.R. No. 95031 March 23, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO GUERRERO y NARES, accused-appellant.
FACTS
The offended party, Analiza Adana, was a minor, 16 years of age, and a mental retardate. In July 1987, in Manila, accused-appellant Mario Guerrero, a 63-year-old laborer and neighbor, beckoned her to his daughter’s house. Once inside, he locked the door, poked a knife at her stomach, forced her to accept a ten-peso bill, and threatened to kill her and her family if she resisted. He then forcibly brought her to a bedroom, removed her clothes, covered her mouth, and had carnal knowledge of her. A similar incident occurred several days later when accused-appellant blocked her path, forced her into the house, again gave her money under threat, and raped her. Analiza did not immediately report the incidents due to fear. Her mother, Hilda Adana, noticed Analiza’s missed menstrual period in August 1987, and the rape was disclosed in September 1987 after her father confronted her. A medical examination confirmed Analiza was no longer a virgin. The defense claimed Analiza and accused-appellant were lovers and that she aggressively pursued sexual relations in exchange for money. The defense presented testimonies from accused-appellant’s wife and daughter, and a friend, who claimed to have witnessed compromising situations between the two.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
The Supreme Court affirmed the judgment of the Regional Trial Court finding accused-appellant guilty of rape. The Court found Analiza’s testimony credible, straightforward, and consistent, and rejected the defense of a love affair as inherently improbable. The Court noted that the trial court properly appreciated Analiza’s mental retardation, which made her incapable of giving valid consent. The award of moral damages was increased to thirty thousand pesos (P30,000.00). However, the portion of the trial court’s judgment ordering accused-appellant to recognize any child born from the rape was deleted, as a married rapist cannot be compelled to recognize the offspring. While the evidence showed two acts of rape, the conviction was sustained for only one crime as the information charged only one offense.