G.R. No. L-47437 September 29, 1983
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GAMELO MARIANO y OBUSAN, accused-appellant.

FACTS

The accused-appellant, Gamelo Mariano y Obusan, a faith healer, was convicted by the Court of First Instance of Camarines Norte for the rape of Socorro Soria, a woman diagnosed with chronic schizophrenia. On September 25, 1976, appellant was treating Socorro in her locked room. Her mother, Maria Soria, and sister-in-law, Elizabeth, peeped through an aperture and witnessed appellant on top of the victim, naked from the waist down, in the act of sexual intercourse. Maria Soria climbed a cabinet, reached into the room, and grabbed appellant’s hair. Appellant fled but was blocked by Elizabeth. He later offered to marry Socorro. A medical examination revealed fresh hymenal tears, corroborating the sexual assault.
Appellant denied the accusation, claiming he had ceased treatment a week prior and merely performed a healing ritual on that date. He also challenged the trial court’s jurisdiction, arguing the complaint for rape was invalidly filed by the victim’s mother while the father was still alive, contending the father held the exclusive right to file under the rules.

ISSUE

The core issues were: (1) whether the prosecution proved beyond reasonable doubt that appellant had carnal knowledge of a demented woman, and (2) whether the complaint filed by the mother conferred jurisdiction on the court despite the father being alive.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court found the evidence of guilt overwhelming. The positive eyewitness testimony of Maria Soria, who had no motive to falsely testify and expose her daughter to scandal, was credible and compelling. This testimony was strongly corroborated by the medical findings of fresh hymenal lacerations, which constituted indubitable proof of penetration. The victim’s mental condition was undisputed, with medical records confirming her chronic schizophrenia. Under Article 335 of the Revised Penal Code, carnal knowledge with a woman of unsound mind constitutes rape as she is incapable of giving rational consent.
On the jurisdictional issue, the Court rejected appellant’s technical argument. While Section 4, Rule 110 of the Rules of Court requires the complaint for rape to be filed by the offended party or her parents, grandparents, or guardian, it does not establish a preferential order among parents or categorically grant the father an exclusive right over the mother. Parental authority is jointly exercised by both parents. The mother, acting to vindicate her daughter’s honor, had the legal capacity to file the complaint. The father’s inaction did not invalidate the mother’s valid complaint, which sufficiently vested jurisdiction in the trial court. The Court emphasized that sustaining such a technicality would defeat the ends of justice.