PEOPLE V.
CORPUZ AAA underwent two neuropsychiatric examinations
FACTS
Respondent Edgar Allan Corpuz was convicted of 4
counts of Simple rape of AAA. Upon presentation
of the Medico Legal Certificate, it was stated that
AAA was pregnant. In addition, AAA underwent 2
neuropsychiatric examinations where it was found
out that she was suffering from Mild Mental
Retardation, and an IQ of 42 and 70 respectively.
During the testimony in the trial, AAA pointed as
Corpuz as the one who raped her as well as the
father of XXX. The trial court ordered a DNA Test
where it concluded that Corpuz was indeed the
father of AAA’s child. Thus the trial court
convicted Corpuz of 4 counts of rape. Upon appeal
by Corpuz, the CA likewise sided with the decision
of the trial court. Thus, the appeal to the Supreme
Court.
Corpuz argued that That AAA’s testimony is
inconsistent when she was interviewed. She testified
that she was rapes at 13 years old, but her first
menstrual period was when she was 14 years old.
Also, Corpuz stated that The DNA paternity test
result is insufficient for his conviction; placing
doubt the accuracy of the doubt
ISSUE
WON Corpuz’ guilt is proven beyond reasonable
doubt
RULING
YES. The guild of Edgar Allan Corpuz was proven
beyond reasonable doubt. The gravamen of rape
under Article 266-A of the RPC is carnal
knowledge of a woman against her will or without
her consent. Moreover, sexual intercourse with an
intellectually disabled person is rape since proof of
force or intimidation is needless when the victim is
incapable of giving her consent. In the case at bar,
in which the result came that she was suffering
mental retardation which amounts to intellectual
incapacity. In People v. Quintos, the stated that a
person’s capacity to decide whether to give
consent or to express resistance to an adult
activity is determined not by his chronological
age, but by his mental age.
The court also states that AAA is capable of being a
witness. A person who has mental disabilities, may
still perceive and is capable of making known his or
her perception to others. One of the doctors who
conducted the neuropsychiatric examination on
AAA concluded that AAA’s degree of honesty is
great as she was able to completely respond to the
questions pertaining to the incident. The trial court
also took notice of AAA’s testimony as categorical
straightforward and credible
Lastly, as regards to the DNA testing, the Court
finds that the accusation made by Corpuz against
the credibility of the DNA test result lack of merit.
It was the defense that moved for the DNA Testing.
He failed to assail the dependability of the
procedure before the trial court. Thus, the SC finds
the respondent ESTOPPED from questioning much
less objecting the reliability of the DNA Testing
methodology conducted.
NOTES
In order to qualify as a witness, the basic test, is
whether or not he or she can perceive, and
perceiving, can make known his or her perception
to others (LOOK FOR RULE 130 FROM THE
ROC)
SECTIONS 7-8 of the Rule on DNA Evidence
provides for the PROBATIVE VALUE of DNA
Evidence.