G.R. No. 186533. August 09, 2010 (Case Brief / Digest)

**Title:** People of the Philippines v. Efren Castillo


The case of *People of the Philippines vs. Efren Castillo* revolves around the conviction of Efren Castillo for the crime of rape committed against a woman identified by the pseudonym AAA, who was proven to be mentally retarded. The crime was committed sometime in March 2000 in Gingoog City, Philippines. AAA, assisting her mother in selling rice cakes, attempted to collect a debt from Castillo, who instead led her to a secluded location and forcibly had sexual intercourse with her.

When arraigned on August 23, 2000, Castillo pleaded not guilty. The trial proceeded without any stipulation of facts during the pre-trial conference. The prosecution presented multiple witnesses, including the victim, a medical doctor who examined her, the victim’s mother, and a guidance psychologist who determined AAA’s mental capacity. Based on their testimonies, the prosecution established that AAA was 18 at the time of the incident, has had epileptic seizures since age nine, and was diagnosed with mental retardation.

Castillo’s defense was primarily denial and alibi, claiming he was elsewhere during the alleged incidents and questioning the victim’s mental condition’s proper evaluation. His father also testified, admitting AAA’s mental retardation.

The Regional Trial Court found Castillo guilty, sentencing him to reclusion perpetua and ordering him to pay civil indemnities. This decision was affirmed by the Court of Appeals with modifications regarding damages awarded to AAA. Castillo’s subsequent appeal to the Supreme Court grounded on the argument that AAA’s mental retardation was not conclusively established and his identification as the perpetrator was insufficient.


1. Whether the prosecution sufficiently proved AAA’s mental retardation.
2. Whether Castillo’s guilt for rape was proven beyond reasonable doubt.

**Court’s Decision:**

The Supreme Court rejected Castillo’s contentions, affirming his conviction. The Court clarified that rape is committed by carnal knowledge of a woman against her will or without her consent, particularly emphasizing that mental retardation of the victim categorizes her as “deprived of reason,” negating the need for evidence of force or intimidation. Evidence other than medical could establish mental retardation, such as witness testimony and the trial judge’s observations.

Moreover, the Court found AAA’s straightforward testimony and the accompanying medical findings sufficient to prove sexual intercourse and enforced carnal knowledge. Castillo’s defenses of denial and alibi were dismissed as inherently weak against the positive identification and consistent testimony of the victim, which was deemed credible and straightforward despite her mental condition.


For the charge of rape to prosper under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, it must be shown that carnal knowledge of a woman was achieved by force or intimidation, or when she was otherwise incapable of giving consent due to reasons including mental retardation. A victim’s testimony can suffice to prove rape if it meets the standard of credibility.

**Class Notes:**

– **Mental Retardation as a Condition Depriving Consent:** Mental retardation in a rape victim negates the need for proof of force, intimidation, or consent, making the act punishable by law.
– **Evidence of Rape:** A victim’s credible testimony, corroborated by medical findings of sexual penetration, is adequate for conviction.
– **Defense in Rape Cases:** Denial and alibi are weak defenses against rape charges, especially when contradicted by the victim’s positive identification and consistent testimony.
– **Witness Testimony on Mental Capacity:** Non-expert witnesses familiar with the victim can testify regarding the victim’s mental condition.
– **Damages:** Civil indemnity and moral damages are mandatory upon the conviction of rape, with the amount dictated by prevailing laws and jurisprudence.

**Historical Background:**

The case underscores the Philippine justice system’s recognition of the vulnerability of individuals with mental retardation in sexual assaults, emphasizing the irrelevance of consent in such scenarios, as consent cannot be given by individuals deemed incapable due to their mental condition. It reinforces legal protections for rape victims, highlighting the importance of credible testimony and the court’s role in assessing the veracity of claims and evidence presented during trials.


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