PEOPLE V. CATIG Y GENTERONI [G.R. No. 225729, March 11, 2020]

 CASE DIGEST

PEOPLE V. CATIG Y GENTERONI

G.R. No. 225729, March 11, 2020

SECOND DIVISION, HERNANDO J.

 

Rape, Mental Retardation

 Doctrine: Any sexual encounter with a person diagnosed with mental retardation, even if the individual seemingly consents, is still considered non-consensual intercourse under the law due to their incapacity to provide informed and valid consent.

 

This involves an alleged incident of rape who was 15 years old at the time, has been diagnosed with moderate mental retardation, which affects her cognitive and decision-making abilities. The prosecution presented testimonies and evidence supporting their claim that the accused forcibly engaged in sexual intercourse with the victim against her will and consent. The defense, on the other hand, asserted that the sexual encounter was consensual and that the victim willingly participated in the act.

 

Whether the accused is guilty of rape under the RPC.

 

YES. The Supreme Court agreed that the sexual act was non-consensual and that the victim's mental retardation rendered her unable to give valid consent. The absence of valid consent is a crucial element in rape cases.

This case raised an essential issue concerning the victim's mental condition and her ability to provide consent. The Court recognized that persons with mental retardation may have limited cognitive capabilities and may not fully comprehend the consequences of their actions. As a result, any sexual encounter with a person diagnosed with mental retardation, even if the individual seemingly consents, is still considered non-consensual under the law due to their incapacity to provide informed and valid consent.

The ruling reinforced the principle that consent must be given freely and intelligently for any sexual act to be considered lawful.

 

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