People v. Mariano
REITERATIONFacts
The Antecedents: Socorro Soria, a 24-year-old woman with unsound and feeble mind, was a mental patient at the National Mental Hospital. She was transferred to a hospital in Camarines Sur and later brought home for treatment by the appellant, Gamelo Mariano, a known faith healer. On September 25, 1976, the appellant went to the Soria residence to treat Socorro. He entered Socorro's room and locked the door from the inside. Socorro's mother and daughter-in-law, while attending to customers, noticed the locked door. They peeped through an aperture and saw the appellant having sexual intercourse with Socorro. The mother climbed onto a cabinet, grabbed the appellant's hair, causing him to stop. Upon being confronted, the appellant expressed willingness to marry Socorro and provide her with a separate dwelling. Socorro was examined by Dra. Amelia Paguirigan, who found abrasions on the labia majora and hymenal tears at the 6, 2, and 9 o'clock positions. The vaginal smear for sperm cells was negative. Procedural History: A complaint for rape was filed by Socorro's mother before the Municipal Court of Daet, Camarines Norte, which led to an information filed before the Court of First Instance of Camarines Norte. The trial court found Gamelo Mariano guilty of rape and sentenced him to reclusion perpetua, to indemnify the offended party, and to pay costs. The Petition: The accused appealed the decision of the trial court.
Issue(s)
Whether the trial court acquired jurisdiction over the case given that the complaint was filed by the mother of the offended party while the father was still living. Whether the evidence presented was sufficient to prove the crime of rape.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused guilty of rape. The Court held that the mother of the offended party had the right to file the complaint, and the evidence presented was overwhelming to establish the commission of the crime.
Ratio Decidendi
On the issue of jurisdiction and the right to file a complaint: The Court affirmed the trial court's jurisdiction, holding that the mother of the offended party had the right to file the complaint for rape. While Rule 110, Section 4 of the Rules of Court and Article 344 of the Revised Penal Code specify who may file a complaint for rape, they do not categorically state that the father has preferential right over the mother. The Court cited People vs. Dela Cruz which held that the father's passivity should not preclude the mother from securing redress for the outrage committed against her daughter. The mother's filing of the complaint was deemed a sufficient compliance with the law, conferring jurisdiction on the court to try the case. The Court emphasized that the purpose of these provisions is to protect the offended party and ensure that prosecution is initiated by those closest to her, and the mother's action was motivated by maternal concern. On the sufficiency of evidence to prove rape: The Court found the evidence regarding the commission of the offense by the appellant to be overwhelming. The positive testimony of the victim's mother, who caught the appellant in the act of sexual intercourse with Socorro, was given significant weight. The Court reasoned that Mrs. Soria could not have given false testimony that would expose her daughter to public ridicule and disgrace unless she was motivated by a genuine desire to vindicate her daughter's honor. This testimony was corroborated by the medical findings of Dra. Amelia Paguirigan, who documented hymenal tears at specific positions, which constitute indubitable proof of penetration. The fact that Socorro was a woman of unsound and feeble mind, as admitted by the appellant himself, further strengthens the conviction, as such a victim is incapable of giving rational consent to sexual intercourse, making the act rape under Article 335, paragraph 2 of the Revised Penal Code.
Main Doctrine
A person who has carnal knowledge with a mentally retarded or demented woman is guilty of rape because she is incapable of giving rational consent. The mother of the offended party, even if the father is living, can file a complaint for rape if the offended party is incapable of filing it herself.