**Facts:**
Moises Caoile, the accused-appellant, was convicted for two counts of rape under two separate Amended Informations filed on January 5, 2006, in the Agoo, La Union Regional Trial Court (RTC). He was accused of raping AAA, a person with a mental age of seven years, on two separate occasions, April 6, 2005, and May 12, 2005. Caoile pleaded not guilty, and a joint trial followed the pre-trial conference.
AAA was cared for by her grandmother and aunt after her mother went overseas. Caoile, a neighbor whose daughter was AAA’s playmate, lured AAA in two instances to secluded locations where he raped her. Dr. Claire Maramat and Dr. Brenda Rosuman testified to finding healed hymenal lacerations and spermatozoa in AAA’s genitalia, indicating sexual intercourse. AAA was also assessed by Claire Baliaga, a psychologist, and Dr. Roderico V. Ramos, a psychiatrist. Both found AAA to be mentally retarded with the mental age of a young child.
Caoile defended himself by claiming a consensual sexual relationship with AAA, stating unawareness of her mental disability, and presenting evidence from Dr. Lowell A. Rebucal to suggest AAA only suffered from Mild Mental Retardation.
**Issues:**
1. The validity of the Amended Informations concerning Caoile’s conviction for rape under the circumstances pertaining to a mental retardate.
2. AAA’s mental condition and its impact on the validity of consent in sexual intercourse.
3. The credibility and competency of AAA as a witness considering her mental retardation.
4. The defense of consent presented by Caoile based on an alleged relationship with AAA.
5. The application of the crime of rape on a mental retardate and the requirement of consent.
**Court’s Decision:**
The Supreme Court affirmed the decision of the Court of Appeals with modification. It held that:
1. The erroneous reference to AAA as “demented” instead of “deprived of reason” in the Amended Informations did not violate Caoile’s rights, as the important facts were correctly conveyed.
2. AAA’s ability to testify straightforwardly was not evidence against her mental retardation. Her condition was confirmed by multiple experts, including one chosen by the defense.
3. Sexual intercourse between Caoile and AAA, given her proven mental retardation, constituted rape since a mental retardate is deemed incapable of giving legal consent.
4. The sweetheart defense was rejected. The law does not require force or intimidation for a rape conviction when the victim is incapable of consenting due to mental retardation.
5. Caoile’s lack of knowledge of AAA’s mental condition does not absolve him, as the crime of rape under these circumstances does not hinge on the accused’s awareness of the victim’s mental capacity.
**Doctrine:**
– Carnal knowledge of a mental retardate constitutes rape under Article 266-A, paragraph 1(b) of the Revised Penal Code, as consent cannot be given by individuals suffering from mental deficiency.
– The courts give significant weight to the trial court’s assessment of witness credibility, especially concerning victims of sexual assault who are mentally retarded.
**Class Notes:**
– In cases of rape where the victim is mentally retarded, consent is legally impossible, and the focus is on the act of intercourse and the mental condition of the victim.
– Mental retardation for legal purposes is significantly determined through expert testimony, encompassing psychological and psychiatric evaluations.
– Defense strategies such as a consensual relationship are invalid when the victim’s mental state renders them incapable of providing informed consent.
– Error in legal terms within charges does not automatically prejudice the accused’s defense if the factual basis of the accusation is clear and sufficiently informative.
**Historical Background:**
This case reiterates the protective stance of Philippine law toward individuals with mental disabilities, especially in contexts of sexual crimes. It underscores the legal principle that mental incapacity negates consent, a cornerstone in prosecuting crimes of sexual abuse against vulnerable individuals. The detailed examination of consent, mental capacity, and witness credibility in this case provides a judicial framework for handling similar future cases with sensitivity and adherence to principles of justice.
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