People of the Philippines vs. Baid (2000) - Case digest
G.R. No. 129667. July 31, 2000
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Facts: That on or about the 22nd day of December 1996, in Quezon City, Philippines, the said accused by means of force and intimidation, to wit: by then and there [willfully], unlawfully and feloniously undressing one NIEVA GARCIA y SABAN, a mental patient suffering [from] schizophrenia and put himself on top of her, and thereafter have carnal knowledge with the undersigned complainant against her will and without her consent.
When arraigned, accused-appellant entered a plea of not guilty, whereupon trial of the case on the merits proceeded. The prosecution presented three witnesses, namely, the complainant, Dr. Herminigilda Salangad, the complainant’s attending psychiatrist, and Dr. Emmanuel Reyes, the medico-legal officer who examined the complainant. Complainant was brought later during the day before Dr. Emmanuel Reyes for medico-legal examination. She told him what happened. Dr. Reyes reduced her narration of the incident into writing and then gave her a physical examination. Accused-appellant testified in his behalf. He stated that he had been a nurse-aide of the Holy Spirit Clinic since September 18, 1995.
He denied the allegations against him. He testified that, on the date and time referred to by the complainant, he was asleep in the nurse-aide quarters located about ten meters from the room where complainant was staying.
On cross-examination, accused-appellant admitted that he knew it was prohibited to give cigarettes to patients. He further admitted that, as a nurse-aide, he could enter the patients’ room anytime to check their condition and see to it that the lights were turned off when they were not needed. He further stated that he was not investigated by the police when he was invited to their headquarters. The trial court rendered its decision finding the accused Eric Baid y Ominta GUILTY beyond reasonable doubt of the crime of rape.
Accused-appellant contends that the trial court erred in convicting him of rape. Dr. Herminigilda Salangad, the complainant’s attending psychiatrist and consultant at the Medical Center in Muntinlupa, the Perpetual Help Medical Center, the Philippine National Police, and the Holy Spirit Clinic, was presented as an expert witness. According to her, complainant was, at the time of the incident, suffering from an undifferentiated type of schizophrenia, described as having the characteristic symptoms of schizophrenia but does not fit the profile for paranoid, disorganized, or catatonic schizophrenia. Dr. Salangad stated that complainant seemed to shift from one type of schizophrenia to another.
It is contended that as complainant is a schizophrenic, her testimony should not have been given credence by the trial court. It is argued that: (1) there were serious inconsistencies between her sworn statement and her testimony in court; (2) the prosecution failed to present witnesses to corroborate her testimony; (3) complainant failed to identify accused-appellant; (4) the results of the medico-legal examination were negative for spermatozoa; (5) the healed lacerations showed that complainant had sexual intercourse seven days before the alleged incident; and (6) the probability was that her allegations of rape were merely a product of her fantasy.
Issue: Whether or not the complainant, who is suffering from schizophrenia, can be qualified as a witness?
Held: Yes. Notwithstanding her mental illness, complainant showed that she was qualified to be a witness, i.e., she could perceive and was capable of making known her perceptions to others.
Her testimony indicates that she could understand questions particularly relating to the incident and could give responsive answers to them. Though she may have exhibited emotions inconsistent with that of a rape victim (“inappropriate affect”) during her testimony, such as by smiling when answering questions, her behavior was such as could be expected from a person suffering from schizophrenia. Otherwise, complainant was candid, straightforward, and coherent.
It has long been settled that a person should not be disqualified on the basis of mental handicap alone.
Whatever may be the inconsistencies in her testimony, they are minor and inconsequential. They show that complainant’s testimony was unrehearsed, and rather than diminish the probative value of her testimony, they reinforce it. In the case at bar, the rape of complainant occurred in a room where other patients were sleeping. This circumstance, it is argued, is antithetical to the possibility of the commission of rape. As this Court has repeatedly said, lust is no respecter of time and place and the crime of rape can be consummated even when the malefactor and the victim are not alone. The plausibility of an allegation of rape does not depend on the number of witnesses presented during the trial, so much so that, if the testimonies so far presented clearly and credibly established the commission of the crime, corroborative evidence would only be a mere surplusage.27 In this case, the trial court gave credence to the testimonies of the prosecution witnesses on the basis of which it adjudged accused-appellant guilty. In the absence of bias, partiality, and grave abuse of discretion on the part of the presiding judge, his findings as to their credibility are entitled to utmost respect as he had the opportunity to observe their demeanor on the witness stand.
Pasong Tamo, Quezon City, Metro Manila, Philippines.
