Case Digest: PEOPLE OF THE PHILIPPINES v. SONNY CANON alias “POGI” 420 SCRA 634 (2004)

PEOPLE OF THE PHILIPPINES v. SONNY CANON alias “POGI” 420 SCRA 634 (2004)

It is inconceivable for a mother to drag a daughter, a mental retard into a rape scam. Sonny Canon alias ―POGI‖(Sonny) was charged and found guilty for raping AAA, a mental retard who has inferior mental capacity and has speech problem known in the local parlance as ―bulol‖. Upon conviction, Sonny went into hiding. AAA got pregnant and delivered a child that thereafter led Sonny to cease from hiding. Sonny subsequently sought settlement with AAA‘s family and proposed to marry AAA but the same was rejected. Upon appeal to the Supreme Court, Sonny contends that he and AAA were sweethearts and that the inconsistencies and lack of clarity in AAA‘s testimonies indicates that her parents have coached and harmed her to impute the crime to him. He likewise contends that the prosecution‘s characterization of AAA as a mental retard based on the mothers‘ testimonies and a medical certificate lacks supporting evidence to convict him of the crime charged.

ISSUE:

Whether or not the prosecution has met the quantum of proof to establish the commission of rape

HELD:

In People v. Duranan, the Court, citing Senator J. Francisco‘s treatise on evidence, laid down the following judicial dictum: The mother of an offended party in a case of rape, though not a psychiatrist, if she knows the physical and mental condition of the victim, how she was born, what she is suffering from, and what her attainments are, is competent to testify on the matter. Sonny‘s insinuation that it was really the victim‘s parents who instituted this rape case deserves scant attention. As was pronounced in People V. Rosare, the Court finds it inconceivable for a mother, like that of AAA‘s, to drag a daughter, a mental retard at that, into a rape scam with all its attendant scandal and humiliation for the flimsiest of reasons that she merely did not want her child to be married to the accused.