People vs. XXX
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Riann BilbaoPeople vs. XXX
Uploaded by
Riann BilbaoPEOPLE vs.
XXX
G.R. 249833, OCTOBER 19, 2022
Facts: The victim’s sister witnessed that accused-appellant XXX raped AAA in the house
they shared with XXX. Medico-legal found healed lacerations in the victim’s hymen and
confirmed that it can be caused by a fully erect male organ. Mental health authorities
also issued a report indicating that AAA has severe intellectual disability, her mental age
being that of a 4-year old child. XXX argues alibi and denial as his defense: particularly,
that that the date of the incident on the Information filed against him and the date
testified by BBB do not match, and filing of the complaint was likely propelled by ill
motive since accused-appellant had a prior violent encounter with AAA's brother. XXX
was convicted in RTC and CA.
Issue: Did the appellate court err in sustaining the conviction of accused-appellant.
Ruling: The SC ruled in the negative and dismissed accused’s appeal. The SC modified
CA’s ruling, and found accused guilty of Rape under paragraph 1 (d), Article 266-A of the
RPC, as amended by RA 8353, with the penalty of reclusion perpetua. It what was
proven during trial is that AAA is intellectually-disabled with mental age below 12 years
old during the act. Such conviction still stands even if there is no explicit mention of
mental retardation or intellectual disability in the Information. An Information that does
not expressly allege mental retardation but mentions the childish mentality of a victim
and with accompanying medical certificate indicating such disability suffice to inform the
accused-appellant of the nature of the charge. The SC also held that the date of
commission is not an essential element of Rape. Minor inconsistencies not touching on
the central fact of the crime do not impair the credibility of witnesses. The SC further
stated that an inherently-weak defense like alibi cannot prevail over a positive and
credible testimony of an eyewitness, especially one that is corroborated by medical
findings.
