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PEOPLE v. MOISES CAOILE

FACTS:

Accused-appellant Moises Caoile was charged with two counts of rape of a demented person. The first case alleged that on April 6, 2005, Caoile had sexual intercourse with the victim, AAA, a demented person with a mental age of seven years old. The second case alleged that on May 12, 2005, Caoile had sexual intercourse with AAA, a demented person with a mental age of seven years old. AAA was left in the care of her grandmother and auntie while her mother worked abroad. Caoile was their neighbor and his daughter, Marivic, was AAA's playmate.

AAA disclosed the abuse when she heard her friend complaining about Caoile's actions. After AAA's aunt reported the incident to the police, AAA was examined by Dr. Claire Maramat, who found multiple healed hymenal lacerations in her genitalia. Dr. Maramat also took seminal fluid samples, which were examined by Dr. Brenda Rosuman. Dr. Rosuman found the presence of spermatozoa and infection caused by hygiene or acquired through sexual intercourse.

During the trial, Dr. Roderico V. Ramos, a psychiatrist, testified that after evaluating AAA, he diagnosed her with moderate mental retardation, with a mental functioning equivalent to that of a 5 or 6-year-old child. The defense claimed that Caoile knew AAA and that she was a frequent visitor in their house. They also claimed that AAA acted like a normal individual and had finished her elementary education.

The RTC found Caoile guilty of two counts of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the RTC ruling with modification, and Caoile now appeals to the Supreme Court, questioning the credibility of AAA and the methods used to determine her mental state.

The prosecution's evidence served as the main basis for Caoile's conviction. He was found guilty under Article 266-A, paragraph 1(d) in relation to Article 266-B, paragraph 1.

ISSUES:

  1. Whether AAA can be considered "deprived of reason" under Article 266-A, paragraph 1(b) of the Revised Penal Code.

  2. Whether the Amended Informations charging Caoile with rape of a demented person under paragraph 1(d) are valid.

  3. Whether the competence and credibility of mentally deficient rape victims as witnesses have been upheld by the Court.

  4. Whether Caoile can impeach his own witness without violating established rules of evidence.

  5. Whether the findings of the experts on AAA's mental condition were sufficient to establish her mental retardation.

  6. Whether the trial court's assessment of the witnesses' credibility should be given weight and be conclusive and binding upon the Court.

  7. Whether sexual intercourse with a mentally disabled person constitutes rape under the Revised Penal Code, as amended.

  8. Whether the knowledge of the perpetrator regarding the victim's mental disability is necessary for the crime to be qualified and punishable by death.

RULING:

  1. The court ruled that AAA, who was clinically diagnosed as a mental retardate, can be properly classified as a person who is "deprived of reason" under Article 266-A, paragraph 1(b) of the Revised Penal Code. Therefore, Caoile's argument attacking AAA's credibility as a mental retardate is not accepted.

  2. Although Caoile was charged with rape of a demented person under paragraph 1(d) in the Amended Informations, the court held that the mistake in the classification of AAA's mental condition as "demented" instead of "deprived of reason" does not exonerate Caoile. It was determined that Caoile's rights were not violated, as the Amended Informations accurately and clearly alleged the elements of the crime charged, and Caoile was able to understand the nature of the charges against him.

  3. The competence and credibility of mentally deficient rape victims as witnesses have been upheld by the Court, provided that they can communicate their ordeal capably and consistently. The testimony of a woman saying she has been raped is sufficient to prove rape if it satisfies the standard of credibility needed to convict the accused.

  4. Caoile cannot impeach his own witness without violating established rules of evidence.

  5. The findings of the experts, based on several tests and examinations, including the Stanford-Binet Test, were sufficient to establish AAA's mental retardation.

  6. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding upon the Court.

  7. Yes, sexual intercourse with a mentally disabled person constitutes rape under the Revised Penal Code, as amended. The absence of the victim's will determines the existence of rape, and lack of will may exist when the victim is suffering from mental deficiency impairing her reason or free will. Therefore, even if the victim does not offer resistance, it does not mean consent, especially when she is incapable of giving rational consent due to her mental condition.

  8. No, the knowledge of the perpetrator regarding the victim's mental disability is not necessary for the crime to be qualified and punishable by death. The Revised Penal Code punishes the rape of a mentally disabled person regardless of the perpetrator's awareness of the victim's mental condition. However, the perpetrator's knowledge of the victim's mental disability at the time of the commission of the crime qualifies the offense and makes it punishable by death.

PRINCIPLES:

  • The term "deprived of reason" in Article 266-A, paragraph 1(b) of the Revised Penal Code includes those suffering from mental abnormality, deficiency, or retardation.

  • To be sufficient, a complaint or information must state the name of the accused, the designation of the offense given by the statute, the acts or omissions constituting the offense, the name of the offended party, the approximate time and place of the commission of the offense, and accurately and clearly allege the elements of the crime charged. The requirement is to inform the accused of the nature of the accusation against him and enable him to suitably prepare his defense.

  • The capacity of a mental retardate to stand as a witness in court has been recognized by the Supreme Court.

  • Mentally deficient rape victims can be competent and credible witnesses if they can communicate their ordeal capably and consistently.

  • Testimony of a rape victim is sufficient to prove rape if it satisfies the standard of credibility needed to convict the accused.

  • Impeachment of one's own witness is not allowed without violating established rules of evidence.

  • Expert findings based on tests and examinations can establish mental retardation.

  • The trial court's assessment of witness credibility is given great weight and is conclusive and binding upon the Court.

  • Sexual intercourse with a mentally disabled person constitutes rape under the Revised Penal Code, as amended.

  • Lack of will on the part of the victim determines the existence of rape when she is suffering from mental deficiency impairing her reason or free will.

  • The knowledge of the perpetrator regarding the victim's mental disability is not necessary for the crime to be qualified and punishable by death under the Revised Penal Code.