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PEOPLE v. MARIO DUMANON Y DUMANACAL

FACTS:

The accused-appellants Mario Dumanon and Ricardo Labrador were charged with rape based on a complaint filed by Dominga Anib on behalf of her mentally retarded daughter, Anacurita Anib. The complaint alleged that the rape occurred on December 2, 1993, at midnight. Supporting the complaint were a medical certificate and affidavits.

After a preliminary examination, the Municipal Circuit Trial Court (MCTC) found a prima facie case for rape and ordered the arrest and detention of Mario and Ricardo without bail. The court also required them to submit their counter-affidavits. However, instead of filing their counter-affidavits, Mario and Ricardo filed a motion to dismiss the case on the grounds that rape cannot be prosecuted de oficio and that the complaint was not signed by the offended party, with no proof of her incapacity.

The MCTC ruled that the complaint was properly filed by Anacurita's mother as she is mentally retarded. The court also found probable cause against Mario and Ricardo and forwarded the case to the Provincial Prosecutor. The Provincial Prosecutor's Office filed a complaint for rape, which was approved and submitted to the Regional Trial Court.

Mario and Ricardo sought a reinvestigation, questioning the unsigned complaint and Anacurita's alleged mental incapacity. The defense also asserted that the prosecution failed to present an eyewitness and that they were deprived of their right to submit counter-affidavits. The prosecution opposed the motion for reinvestigation, stating that Mario and Ricardo failed to submit their counter-affidavits.

The trial on the merits started and the prosecution presented Anacurita, Dominga Anib, Eduardo Dizon, and Dr. Gregoria Beberino-Comelon as witnesses. Anacurita testified that she was raped by both Mario and Ricardo on the night of December 2, 1993. She identified the accused as her friends and townmates. Dominga Anib testified about the events surrounding the rape and her relationship with the accused.

On December 2, 1993, Dominga Anib found Anacurita in Jaime Batac's house, holding her underwear and with her hair and dress soiled. Anacurita revealed that she had been raped by Ricardo and Mario. Dominga immediately reported the incident to the barangay captain and later to the police. Anacurita was brought to the hospital, where evidence of fresh injuries was noted.

Eduardo Diaz testified that he saw Mario and Ricardo on the night of December 2, 1993, and later heard Dominga berating Anacurita for coming from Jaime's house. Eduardo accompanied Dominga to report the incident, and both Mario and Ricardo were arrested.

Mario claimed that he and Anacurita were lovers and that she consented to their sexual intercourse. The defense did not call Ricardo as a witness.

After both parties presented their case, the trial court found Mario and Ricardo guilty based on Anacurita's credible testimony and supported by the medical findings. The court also considered Mario's version as implausible and Ricardo's silence as an admission of guilt.

ISSUES:

  1. Whether or not Mario Dumanon and Ricardo Labrador can be convicted of rape for an alleged act committed against a mentally deficient individual without clear medical or expert evidence.

  2. Whether the trial court erred in convicting the accused-appellants of the crime of rape committed with the use of force and intimidation.

RULING:

  1. The Supreme Court upheld that mental retardation can be proven by evidence other than medical expert testimony. The personal observation of the trial judge would suffice in determining the impact on the victim of the force and intimidation involved in the crime of rape, especially against a mentally deficient person like Anacurita Anib.

  2. The Supreme Court affirmed the conviction of Mario Dumanon and Ricardo Labrador for rape, emphasizing that the trial court properly found the presence of force and intimidation in the commission of the crime. The force required to rape a mentally deficient person is of a lesser degree than that used against a normal adult. The Court upheld that there was sufficient force and intimidation to constitute rape, considering the mental state of Anacurita.

PRINCIPLES:

  1. Proof of Mental Retardation: Mental deficiency can be proven through evidence other than medical or expert testimony. Personal observations by the trial judge of the victim's condition can be deemed sufficient.

  2. Force and Intimidation in Rape: The degree of force or intimidation needed to consummate rape is relative and can vary depending on the victim's mental and physical condition. The force required to overcome a mentally deficient individual may be less than that needed for a normal adult.

  3. Offer of Compromise as Admission of Guilt: An offer to compromise by the accused can be considered as an implied admission of guilt under Section 27, Rule 130 of the Rules of Court.

  4. Civil Indemnity and Moral Damages: Civil indemnity of P50,000 and moral damages of P50,000 were awarded to the victim as compensation for the rape, in accordance with current jurisprudence, even without specific proof of moral suffering.