### Facts:
In Bulacan, Philippines, XXX was charged with two counts of Qualified Rape against AAA, a 23-year-old mentally retarded woman, in February and July 2004. The case proceeded from arraignment, where XXX pleaded not guilty, to trial at the Regional Trial Court (RTC) of MMM, Bulacan, and eventually to appeal at the Court of Appeals (CA) and the Supreme Court.
#### Prosecution’s Narrative:
AAA, living with her condition and epilepsy, was raped twice by XXX, her sister’s husband, under the pretext of curing her epilepsy. She was found pregnant, and subsequent medical examinations confirmed her pregnancy and mental retardation. The prosecution also highlighted AAA’s mental incapacity to consent, reinforced by expert psychological testimony.
#### Defense’s Position:
XXX denied the allegations, presenting an alibi that he was in Nueva Ecija during the alleged incidents. He requested a DNA examination to prove non-paternity, which unfortunately for him, confirmed his biological link to AAA’s child.
### Procedural Posture:
XXX’s conviction of two counts of rape by the RTC was affirmed by the CA, with modifications to damages awarded. Seeking further relief, XXX appealed to the Supreme Court.
### Issues:
1. Whether XXX can be guilty of Qualified Statutory Rape given AAA’s mental condition which rendered her incapable of consent.
2. The credibility of a mentally retarded victim as a competent witness.
3. The relevance and implication of DNA evidence in affirming paternity and, by extension, the act of rape.
### Court’s Decision:
The Supreme Court affirmed the CA’s decision with modifications on the qualified crime committed. It found XXX guilty of Qualified Statutory Rape, considering AAA’s mental incapacity equivalent to a minor below 12 years old, making consent irrelevant. The claim regarding AAA’s credibility due to her mental condition was dismissed as her testimony meets the standards of credibility. The DNA evidence further cemented XXX’s guilt, establishing a biological link to AAA’s child, which he failed to rebut.
### Doctrine:
The Court reiterated the doctrine that when a victim is mentally incapacitated in a manner comparable to a minor below 12 years old, the crime of rape could be classified as Statutory Rape under Article 266-A, paragraph 1(d) of the Revised Penal Code. Additionally, the judgment underscored the principle that DNA evidence, when properly collected, analyzed, and preserved, is a potent tool in establishing paternity, which can be crucial in rape cases involving pregnancy.
### Class Notes:
– **Elements of Rape**: Carnal knowledge of a woman achieved through force, threat, or intimidation, or when the victim is incapable of giving consent due to age or mental capacity.
– **Qualified Statutory Rape**: Statutory rape becomes qualified and warrants greater penalty when the offender is aware of the victim’s mental incapacity.
– **DNA Evidence**: Establishes a biological link that, in the context of rape resulting in pregnancy, can corroborate the victim’s testimony.
– **Credibility of Witnesses with Mental Retardation**: Not undermined by their condition; their testimony is credible if it is coherent and consistent.
### Historical Background:
The Court’s decision reflects the evolving jurisprudence in protecting mentally incapacitated individuals and the acceptance of DNA evidence in the Philippine legal system. It also illustrates the judiciary’s interpretation of laws in light of social and scientific advancements, ensuring justice is accessible and exacting in contemporary contexts.
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