Case Digest: PEOPLE OF THE PHILIPPINES v. JESUS MACAPAL, JR. 463 SCRA 387 (2005)

PEOPLE OF THE PHILIPPINES v. JESUS MACAPAL, JR. 463 SCRA 387 (2005)

While it may be difficult to determine the credibility of one who is a mental retardate, it can still be attained by deducing from the manner he or she testifies in court as to the surrounding facts of the crime committed AAA, a mentally retarded person alleges that appellant Jesus Macapal Jr. raped her by means of force and intimidation. During the arraignment, Macapal pleaded not guilty. The doctor opined that while mental capacity of victim is comparable to that of a child between 9 to 12 years old, she could testify in court under closed door and leading questions should be avoided as retarded people may be suggestible and wish to please others. Dr. Selim, on the other hand testified that the victim was pregnant. Macapal denied the allegations, and alleged that the victim has a boyfriend named Edsel. He contends that the Edsel could have impregnated the victim. Another witness name Mansueto Pande testified that he witnessed the victim and Edsel having sexual intercourse in the house of Nelson Gultiano. Sebastian Bermudez (Bermudez) likewise testified that Macapagl could not have committed the rape because he was in the farm of Bermudez working as helper. The Regional Trial Court (RTC) of Butuan rendered decision finding accused Jesus Macapal, Jr. guilty beyond reasonable doubt of the crime rape. On appeal, the Court of Appeals affirmed the conviction.

 
ISSUE:

Whether or not AAA, a mental retardate, proved beyond reasonable doubt the guilt of Macapagal

HELD:

In rape cases, the victim‘s credibility is crucial to the determination of the accused‘s culpability as the crime generally involves two persons only and usually perpetrated in seclusion. While it may be difficult to determine the credibility of one who is a mental retardate, it can still be attained by deducing from the manner he or she testifies in court as to the surrounding facts of the crime committed. As long as a witness‘ testimony is straightforward, candid and unflawed by inconsistencies or contradictions in its material points, and his or her demeanor is consistent with one who has been victimized to thus bolster credibility with the verity born out of human nature and experience, as in the herein victim‘s case, credibility can be accorded to him or her. In People v. Limio, the complainant‘s low intelligence notwithstanding, this Court entertained no doubt in her testimony, it having categorically showed that ―she had been subjected to a harrowing unspeakable experience, which left an indelible impression in her mind‖ as a rape victim. In the case at bar, albeit the victim‘s testimony was tainted with inconsistencies, these are mere collateral and minor matters which would not compel this Court from discrediting her testimony, given her mental retardation. In fact, testimonial discrepancies, which could have been caused by the natural fickleness of memory, tend to strengthen, rather than weaken, credibility as they negate any suspicion of rehearsed testimony and do not destroy the substance of the victim‘s testimony.