PEOPLE OF THE PHILIPPINES VS. REYNALDO UMANITO G.R. No.

208648
Petition for Review on Certiorari

FACTS: Reynaldo Umanito, was charged with Rape of 19-year old mental retardate, who
personally testified that it was the former who raped and impregnated her against her will
and consent. It happened sometime on March, 2005 or prior thereto at Purok Rosas,
Barangay San Jose, Municipality of President Quirino, Province of Sultan Kudarat,
Philippines. The rape had produced a baby boy who was born on December 10, 2005.
During the arraignment, AAA testified using a sign language assisted by an interpreter.
When she was inquired what appellant did to her, she tapped her thigh with her two
fingers, which was interpreted as sexual intercourse. Moreover, AAAs mother, testified
that sometime in August 2005, she noticed that AAAs belly was growing. She
corroborated it by explaining that they immediately sought assistance from the barangay
upon learning the identity of the culprit. AAA was made to undergo a medical
examination. Thereafter, Dr. Jocelyn Tadena issued a medical certificate stating the
mental and health condition of AAA.
RTC convicted Reynaldo Umanito of rape and sentencing him to suffer the penalty of
Reclusion Perpetua. The Court of Appeals affirmed in toto the judgment of RTC. In the
supplemental brief filed before the Supreme Court, the accused-appellant denied all the
accusations. Appellant contends that AAAs testimony is vague to warrant his conviction.
He elaborates that proof of carnal knowledge, an essential element of rape, could not be
deduced from AAAs gesture of tapping her two fingers.
ISSUE: Whether or not the accused is guilty of the crime of rape?
Whether or not the mere testimony in gestures of the victim enough to convict the
accused-appellant beyond reasonable doubt?

HELD: Yes, he is guilty of the crime of simple rape. Carnal knowledge of a woman who is
a mental retardate regardless of age is rape under Article 266-A, paragraph 1(b) of the
Revised Penal Code, as amended by Republic Act No. 8353. This is because a mentally
deficient person is automatically considered incapable of giving consent to a sexual act.
When a woman says that she has been raped, she says in effect all that is necessary to
show that rape has in fact been committed. Thus, the lone testimony of the victim in a
prosecution for rape, if credible, is sufficient to sustain a verdict of conviction. The only
evidence that can be adduced to establish the guilt of the accused is usually only the
offended partys testimony. In the case of mentally-deficient rape victims, mental
retardation per se does not affect credibility. A mental retardate may be a credible witness.
The acceptance of her testimony depends on the quality of her perceptions and the
manner she can make them known to the court.
WHEREFORE, the Petition for Review on Certiorari is DENIED. The Decision of the Court of
Appeals dated May 30, 2013 finding accused-appellant Reynaldo Umanito guilty beyond
reasonable doubt of the crime of simple rape and sentencing him to suffer the penalty of
reclusion perpetua is AFFIRMED with MODIFICATION. The appellant is further ordered to
pay AAA exemplary damages and interest.