FACTS:

In this case, Eusebia Paloa filed a criminal complaint against Joel Gabawa, accusing him of raping her on July 10, 1996. The complaint stated that Gabawa took advantage of Paloa's mental derangement, making her unable to freely consent to the sexual act. During the trial, witnesses testified, including Teresita Alarba, Dr. Sharon Faith Pagunsan, Dr. Mariano Hembra, and SPO2 Ma. Mae Palabrica. Alarba testified that Gabawa had massaged Paloa's shoulders and chest on the day of the incident. The following day, Paloa was found with injuries in her genital area. Dr. Pagunsan, who examined Paloa, confirmed that the injuries were consistent with those caused by sexual intercourse. Dr. Hembra, a psychiatrist, evaluated Paloa and concluded that she was suffering from chronic schizophrenia during the alleged rape. Paloa herself testified and stated that Gabawa had raped her despite her resistance.

In the trial court's decision, Gabawa was found guilty beyond reasonable doubt of the crime of rape and was sentenced to reclusion perpetua. Gabawa appealed the decision, arguing that the prosecution's evidence was insufficient. The defense did not present any witnesses but offered the medical report as evidence.

ISSUES:

1. Whether Eusebia, the alleged rape victim, is competent to testify on the rape incident despite suffering from chronic schizophrenia.

2. Whether Eusebia's testimony regarding the rape incident is credible.

3. Whether the insanity or intellectual weakness of a witness is a valid objection to her competency.

4. Whether Eusebia's testimony is credible and deserving of full faith and credit.

5. Whether Eusebia's alleged lack of resistance affects the credibility of her testimony.

RULING:

1. Eusebia, despite suffering from chronic schizophrenia, is competent to testify on the rape incident. Mental deficiency affects the weight accorded to the testimony, not its admissibility. As long as Eusebia's mental condition or mental maturity is not impaired at the time of her production for examination, she can testify. It was established that schizophrenia does not result in a clouding of consciousness or gross deficits of memory. Although Eusebia may have had impaired judgment, this does not render her incompetent to testify. Thus, she can testify on the rape incident.

2. The trial court's appreciation of Eusebia's competence to testify is upheld. The court relied on the evaluation of Dr. Hembra, an expert witness, who testified that Eusebia, after recovering from chronic schizophrenia, could understand her surroundings and distinguish truth from hallucination. Dr. Hembra also stated that once the patient has recovered, she can control her faculties, make proper judgments, and perceive events objectively. There is no reason to doubt Dr. Hembra's expertise and integrity. Therefore, Eusebia's testimony regarding the rape incident is considered credible.

3. The insanity or intellectual weakness of a witness is not a valid objection to her competency if, at the time she is testifying, she has the mental capacity to distinguish between right and wrong, understands the nature and obligation of an oath, and can give a fairly intelligent and reasonable narrative of the matters about which she testifies.

4. Eusebia's testimony is plain, straightforward, to the point, and unflawed by any material or significant inconsistency. It is deserving of full faith and credit.

5. The alleged lack of resistance on Eusebia's part does not affect the credibility of her testimony. Her testimony indicates that she understood questions relating to the incident and gave responsive answers to them.

PRINCIPLES:

• In rape cases, the gravamen of the offense is carnal knowledge against the victim's will or without her consent.

• To prove rape, it is not necessary to show complete insanity or deprivation of reason. Mental abnormality or deficiency, including schizophrenia, may be sufficient.

• Mental deficiency affects the weight accorded to a witness's testimony, not its admissibility.

• Adjudication of feeblemindedness or unsoundness of mind does not render a witness incompetent, as long as the mental condition or mental maturity is not impaired during testimony.

• Schizophrenic persons do not suffer from a clouding of consciousness and gross deficits of memory.

• The insanity or intellectual weakness of a witness is not a valid objection to her competency if she has the mental capacity to distinguish between right and wrong, understands the nature and obligation of an oath, and can give a fairly intelligent and reasonable narrative of the matters about which she testifies.

• The testimony of a witness that is plain, straightforward, and unflawed by material or significant inconsistency deserves full faith and credit.

• Tenacious resistance or persistent physical struggle is not required in a rape case.

• The burden of proving resistance is not imposed on the rape victim.

• Corroboration of the victim's testimony by medical findings and positive identification is enough to establish rape.

• Sexual intercourse with an insane, deranged, mentally deficient, feeble-minded, or idiotic woman is considered rape.