FACTS:

The accused-appellant, Martin Nerio Jr., was charged with the crime of rape against a mentally disabled girl named AAA. The incident allegedly occurred on February 26, 2003, when Nerio forcibly brought AAA to his residence and had sexual intercourse with her without her consent. During trial, the prosecution presented evidence including testimonies from AAA's adoptive parents and a medical examination report which showed hymenal laceration. The defense, on the other hand, claimed that AAA joined them during a picnic and they took her home because she refused to leave. Nerio and his mother testified that AAA slept downstairs with them, while Nerio's sisters slept upstairs. The Regional Trial Court found Nerio guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the RTC's decision. Nerio filed a petition for review before the Supreme Court, arguing that there can be no finding of guilt beyond reasonable doubt without the presence of the victim during trial.

ISSUES:

1. Can there be a finding of guilt beyond reasonable doubt in the crime of rape even if the victim, who is mentally disabled, was not presented in court during trial to substantiate the accusation in the criminal information?

RULING:

1. The Court found the petition to be devoid of merit. The accused was found guilty beyond reasonable doubt of the crime of rape. The court affirmed the decision of the trial court, which sentenced the accused to Reclusion Perpetua and ordered him to pay the victim civil indemnity and moral damages.

PRINCIPLES:

• Mental retardation refers to a chronic condition characterized by impaired intellectual functioning measured by standardized tests.

• Rape, as defined in Article 266-A of the Revised Penal Code, can be committed by a man who has carnal knowledge of a woman under any of the circumstances enumerated in the law.