People v. Constantino
REITERATIONFacts
The Antecedents: The victim, AAA, a 15-year-old mentally-retarded girl, was discovered to be pregnant. Her grandmother reported the matter to the barangay. During barangay investigation, AAA identified appellant Mario Constantino as the rapist after initially clearing other individuals. AAA testified that appellant raped her three times under a duhat tree, using a bolo and threatening her on the first two occasions, but not on the third. She also stated she enjoyed the sexual intercourse and asked for more. Procedural History: The Regional Trial Court (RTC) found appellant guilty beyond reasonable doubt of two counts of rape under Article 335 of the Revised Penal Code and sentenced him to reclusion perpetua for each count. He was acquitted of the third rape charge due to insufficiency of evidence. The RTC awarded AAA ₱50,000 as civil indemnity and ₱100,000 as moral damages. The Court of Appeals (CA) affirmed the RTC decision, ruling that inconsistencies in AAA's testimony were understandable given her mental condition, but her positive identification of appellant was credible. The Petition: Appellant appealed the CA decision affirming his conviction for two counts of rape.
Issue(s)
Whether appellant is guilty beyond reasonable doubt of two counts of rape. Whether the victim's positive identification of the appellant is sufficient to sustain conviction despite her mental deficiency and alleged inconsistencies in her testimony. Whether the trial court erred in acquitting appellant of the third rape charge. Whether the awarded civil indemnity and moral damages are proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modifications. Appellant Mario Constantino was ordered to pay AAA ₱100,000 as civil indemnity for the two counts of rape and to provide support for AAA's offspring, the amount and terms to be determined by the trial court. The Court upheld the conviction for two counts of rape but could not reverse the acquittal for the third charge due to double jeopardy.
Ratio Decidendi
On the guilt for two counts of rape: The Court held that the prosecution established all the elements of rape under Article 335 of the Revised Penal Code. The victim's positive identification of appellant as her rapist, despite her mental deficiency, was given significant weight and prevailed over appellant's defenses of denial and alibi. The Court noted that it would take appellant only about two hours to travel from his claimed location in Zambales to the scene of the crime in Pangasinan, rendering his alibi weak. Furthermore, the Court found that threatening AAA with a bolo constituted intimidation sufficient to compel her submission to appellant's sexual desires. The Court also pointed out that having sexual intercourse with a female whose mental age is below 12 years old, even if she voluntarily submitted, constitutes rape under Article 335 of the Revised Penal Code. On the victim's testimony and identification: The Court reiterated the consistent ruling that a victim's positive identification of the accused is a powerful piece of evidence that generally prevails over the inherently weak defenses of denial and alibi. While acknowledging the victim's mental deficiency, the Court found that her inconsistencies were expected and did not detract from her ability to communicate her traumatic ordeal and positively identify her assailant. The Court also rejected the contention that the victim's grandmother coached her, finding it highly unnatural for a grandmother to expose her granddaughter to the shame of a rape trial if it were not true. The Court emphasized that it would be difficult for a child with a mental age of a 7-year-old to concoct such a grave charge and narrate its details if it were not the truth. On the acquittal of the third rape charge: The Court acknowledged that the trial court erred in acquitting appellant of the third charge based on the victim's statement that she enjoyed the sexual intercourse. However, the Court held that reversing this acquittal would amount to a patent violation of appellant's right against double jeopardy. Therefore, the conviction for only two counts of rape was upheld. On civil liability: Citing Article 345 of the Revised Penal Code, the Court affirmed appellant's obligation to acknowledge the offspring and provide support. The Court increased the civil indemnity from ₱50,000 to ₱100,000, stating that this amount is mandatory upon the finding of the fact of rape. The amount of support for the child was to be determined by the trial court after due notice and hearing.
Main Doctrine
The positive identification of the accused by the victim prevails over the defenses of denial and alibi. Threatening a victim with bodily injury while holding a bolo constitutes intimidation sufficient to compel submission to sexual desires. Having sexual intercourse with a female whose mental age is below 12 years old, even if she voluntarily submitted, is rape under Article 335 of the Revised Penal Code.