FACTS:

The case involves an appeal filed by Edgar Allan Corpuz y Flores (Allan) from the decision of the Court of Appeals affirming his conviction for four counts of Simple Rape of AAA, a mentally retarded (intellectually disabled) individual with a mental age of five years and eight months. Allan was charged with raping AAA on four separate occasions in 2002 at Brgy. Puelay, Villasis, Pangasinan.

The testimonies of various witnesses, including AAA, her family members, and medical professionals, were presented during the joint trial on the merits. AAA's mother, BBB, testified that AAA informed her about the rape, and they later confirmed that Allan was the perpetrator. CCC, AAA's older sister, also testified and corroborated the incident. EEE, a neighbor of AAA, testified that AAA sought her help when she suspected she was pregnant after drinking a substance to induce menstruation. EEE then called AAA's uncle, GGG, who confirmed AAA's pregnancy and reported the incident to the police and the National Bureau of Investigation.

Dr. Araos-Liberato, a medical officer, issued a medical certificate documenting AAA's injuries and pregnancy. Brenda Tablizo, a psychologist, conducted AAA's neuropsychiatric examination. The defense stipulated to admit AAA's statements and the medical certificate, waiving her testimony.

AAA, a mentally disabled individual with a mental age of 5 to 7 years old, testified that Allan, the accused, had sex with her on four occasions when she was 13 years old. She also confirmed that Allan was the father of her child, XXX.

AAA's testimony was supported by the findings of Dr. Tablizo, who conducted a neuropsychiatric examination on AAA and observed her difficulty in interpersonal relations and poor impulse control. Dr. Acosta also examined AAA and confirmed her mild degree of mental retardation and an Intelligence Quotient of 70.

The defense presented Allan and his daughter as witnesses, who denied the accusations and claimed that AAA's allegations were fabricated by AAA's father.

Upon motion, a DNA paternity test was conducted and it was determined that Allan was the biological father of XXX.

The trial court convicted Allan of four counts of simple rape, considering AAA's credible and categorical testimony, her healed hymenal lacerations, pregnancy, and delivery of a child, as well as the corroboration provided by other witnesses and the DNA paternity test result. Allan appealed his conviction.

The appellant, referred to as Allan in the case, was charged with multiple counts of rape committed against AAA, an intellectually disabled person. The RTC found Allan guilty and sentenced him to reclusion perpetua for each count of rape, as well as ordered him to pay AAA P50,000.00 as civil indemnity and P50,000.00 as moral damages in each case. Allan appealed his conviction, arguing that his guilt was not proven beyond reasonable doubt and that the DNA paternity test result was unreliable. The Court of Appeals affirmed his conviction, and the case was elevated to the Supreme Court. The sole issue for resolution is whether Allan's guilt was proven beyond reasonable doubt.

The accused, a man, was charged with rape in violation of Article 266-A of the Penal Code, as amended by Republic Act No. 8353. The law provides that rape is committed by a man who has sexual relations with a woman under various circumstances. These include when it is done through force, threat, or intimidation; when the victim is deprived of reason or is unconscious; when it is done through fraudulent machination or grave abuse of authority; or when the victim is under 12 years of age or demented. It is also considered rape when any person, under the aforementioned circumstances, commits a sexual assault by inserting his penis into another person's mouth or anal orifice, or any instrument or object into the genital or anal orifice of another person. To secure a rape conviction under Article 266-A, it must be proven that a man had carnal knowledge with a woman, or that a person sexually assaulted another, under any of the specified circumstances.

ISSUES:

1. Whether the sexual congresses between Allan and AAA were proven beyond reasonable doubt.

2. Whether Allan's acts amounted to rape under Article 266-A 1(d) of the Revised Penal Code, as amended.

3. Whether an intellectually disabled person is automatically deprived of reason.

4. Whether a person's capacity to give consent is determined by chronological age or mental age.

5. Whether an intellectually disabled person is qualified to testify as a witness.

6. Whether an intellectually disabled person is a credible witness.

7. Whether the failure of the victim to offer any testimony as to when and where she was raped affects the credibility of her testimony in a rape case.

8. Whether minor discrepancies in the victim's testimony regarding trivial details affect her credibility in a rape case.

9. Whether the victim's intellectual disability affects the credibility of her testimony in a rape case.

10. Whether proof of DNA analysis is necessary to establish the guilt of the accused in a rape case.

11. Whether the result of the DNA testing is admissible as evidence to establish paternity.

12. Whether the DNA testing result is sufficient to establish paternity in this case.

13. Whether or not the crime of rape committed by the accused can be considered as a qualified rape.

RULING:

1. The sexual congresses between Allan and AAA were proven beyond reasonable doubt. AAA positively identified Allan as the father of her child and testified that Allan had sexual intercourse with her multiple times when she was 13 years old. This was corroborated by the Medico Legal Certificate which showed the presence of healed hymenal lacerations. The defense's denial and allegation of fabrication were deemed self-serving and absurd. The trial court found no apparent indications that AAA's father had ill-feelings against Allan, making it unlikely for him to fabricate charges just for vengeance.

2. Allan's acts amounted to rape under Article 266-A 1(d) of the Revised Penal Code, as amended. AAA's intellectual disability was undisputed and well substantiated by medical examinations. Proof of force or intimidation becomes needless in the case of sexual intercourse with an intellectually disabled person, as they are incapable of giving consent. AAA's mental age was that of a child aged five to seven years, establishing her as a demented person under the law.

3. An intellectually disabled person is not automatically deprived of reason or considered demented.

4. A person's capacity to give consent is determined by their mental age, not their chronological age.

5. An intellectually disabled person is qualified to testify as a witness, depending on their ability to relate what they know.

6. An intellectually disabled person can be a credible witness if they are capable and consistent in narrating their experience, and their degree of honesty is great despite their condition.

7. The date, place, and time of the incidents need not be accurately established in a rape case, as they are not elements of rape. The failure of the victim to offer any testimony as to when and where she was raped does not affect the credibility of her testimony.

8. Minor discrepancies in the victim's testimony regarding trivial details do not prejudice her credibility. In fact, such inconsistencies tend to strengthen her credibility as they discount the possibility of rehearsed testimonies.

9. The intellectual disability of the victim may result in slight contradictions in her testimony, but this does not affect her credibility.

10. Proof of DNA analysis is not necessary to establish the guilt of the accused in a rape case.

11. Section 9 of the Rule on DNA Evidence states that if the DNA results exclude the putative parent from paternity, it shall be conclusive proof of non-paternity. If the value of the Probability of Paternity is less than 99.9%, the results of the DNA testing shall be considered as corroborative evidence. If the value of the Probability of Paternity is 99.9% or higher, there shall be a disputable presumption of paternity. Based on the result of the DNA test conducted in this case, Allan is disputably presumed to be the child's father.

12. The result of the DNA testing showed a complete match in all of the tested loci, with a 99.9999% Probability of Paternity. This is considered as corroborative evidence of Allan's paternity. However, the probative value of the DNA evidence should still be assessed considering factors such as the chain of custody, DNA testing methodology, reliability of the testing result, and compliance with scientific standards. In this case, the defense failed to assail the result and dependability of the DNA testing procedure before the trial court, and it is now estopped from questioning the reliability of the DNA testing methodology.

13. The accused can only be convicted of four (4) counts of rape under Article 266-A 1(d) of the Revised Penal Code, as amended, and not as qualified rape. The qualifying circumstance of the victim's mental disability should have been alleged in the Information.

PRINCIPLES:

• To warrant a rape conviction under Article 266-A, it should be shown that a man had carnal knowledge with a woman, or a person sexually assaulted another, under specified circumstances. These circumstances include force, threat, intimidation, deprivation of reason, unconsciousness, fraudulent machination, grave abuse of authority, victim being under 12 years of age, or victim being demented.

• Healed or fresh hymenal lacerations are the best physical evidence of forcible defloration.

• Proof of force or intimidation becomes needless in cases where the victim is intellectually disabled, as they are incapable of giving consent.

• The terms "deprived of reason" and "demented" should be differentiated from "mentally retarded" or "intellectually disabled."

• Capacity to give consent depends on mental age, not chronological age.

• Intellectual disability does not automatically disqualify a person from being a witness.

• The competence and credibility of mentally deficient rape victims as witnesses can be upheld if they can communicate their ordeal capably and consistently.

• Accusations of rape from a woman should be given weight if her testimony withstands the test of credibility.

• The credibility of the victim's testimony is crucial in rape cases, and deference is given to the findings of the trial court regarding credibility, absent strong and cogent reasons to disregard them.

• Examination of witnesses' demeanor during trial, especially in rape cases, is important in establishing the moral conviction of the accused's guilt beyond reasonable doubt.

• Discrepancies in the victim's testimony regarding minor details that do not touch upon the central fact of the crime do not prejudice her credibility.

• The intellectual disability of the victim may result in slight contradictions in her testimony, but this does not undermine her credibility.

• The date, place, and time of the incidents need not be accurately established in a rape case, as they are not elements of rape.

• Proof of DNA analysis is not necessary to establish the guilt of the accused in a rape case.

• The result of a DNA test can establish paternity if it shows a complete match and a high probability of paternity, but the court should still assess the probative value of the DNA evidence.

• The court should consider factors such as the chain of custody, DNA testing methodology, and reliability of the testing result in evaluating the probative value of DNA evidence.

• A denial as a defense is weak and crumbles in the face of positive identification by truthful witnesses.

• Rape is qualified when the offender knew of the mental disability, emotional disorder, and/or physical handicap of the offended party at the time of the commission of the crime. (Art. 266(10) of the Revised Penal Code)

• The qualifying circumstance of rape should be particularly alleged in the Information. A mere assertion of the victim's mental deficiency is not enough. (Art. 266 of the Revised Penal Code)

• When the circumstances call for the imposition of reclusion perpetua only, the civil indemnity, moral damages, and exemplary damages should each be awarded in the amount of P75,000.00. (People v. Jugueta)