PEOPLE OF THE PHILIPPINES, vs. JOSE ANTONIO Y SIOBAL.
- G.R. Number: G.R. No. 107950
- Promulgated: 1994-06-17
- Ponente: Davide, Jr., J.
Doctrine
Positive (affirmative) testimony is stronger than negative testimony; the lone credible testimony of a rape victim can suffice to sustain conviction. (¶108)
Victim's special condition (mental retardation) warrants higher moral damages; courts may increase awards considering the victim's condition. (¶109)
A conviction not based on force or intimidation may still stand where elements of rape under law are otherwise satisfied; appellate affirmation is proper when evidence proves guilt beyond reasonable doubt. (¶72, ¶110)
Facts
Complainant Adela Carbonell filed a criminal complaint accusing Jose Antonio y Siobal of raping her daughter Mercedita on 22 December 1988; complaint supported by sworn statements and a medical certificate. (¶4)
The MCTC issued and served an arrest warrant, received the accused's counter-affidavits, found sufficient evidence to hold him for trial, and transmitted records to the Provincial Prosecutor. (¶5)
The trial court convicted Jose Antonio of rape and sentenced him to reclusion perpetua, plus P10,000 moral damages; the conviction was not predicated on carnal knowledge through force or intimidation. (¶72, ¶73)
Issues
Whether the degree of the victim Mercedita's mental retardation deprived her of reason such that carnal knowledge of her may be considered rape under paragraph 2, Article 335, RPC.
Ruling
The Court found the accused guilty beyond reasonable doubt of rape and affirmed the RTC conviction, ordering payment of increased moral damages and costs. (¶72, ¶110, ¶111)
The Court increased moral damages from P10,000 to P40,000 considering the victim's condition as a retardate. (¶109)
Keywords
G.R. No. 107950, PEOPLE OF THE PHILIPPINES v. JOSE ANTONIO Y SIOBAL, criminal complaint, rape, medical certificate, warrant for arrest, preliminary investigation, application for bail, Regional Trial Court, accused's plea of not guilty, trial on the merits, violence and intimidation, sexual intercourse, mental illness or deficiency, Art. 335 of the Revised Penal Code, organic mental disorder, epilepsy, head trauma, meningitis, mercedita