G.R. No. 174066; October 12, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ERNESTO NARZABAL y CASTELO, JR., Accused-Appellant.

FACTS

Accused-appellant Ernesto Narzabal was charged with the special complex crime of Rape with Homicide. The prosecution evidence established that on the evening of March 2, 2002, the 18-year-old victim, AAA, went missing after leaving to watch television at a neighbor’s house. Her mother, BBB, later heard screams emanating from the direction of Narzabal’s house, which was nearby. Assisted by barangay officials, they proceeded to Narzabal’s residence. Upon entry, they discovered AAA’s lifeless body, half-naked from the waist down, without her underwear, and with blood stains between her legs and oozing from her ears and nostrils. The autopsy report confirmed contusions and abrasions on her genitalia, as well as superficial hymenal lacerations, with the cause of death being cardio-respiratory arrest due to cerebral hemorrhage and skull fracture.
In his defense, Narzabal admitted to killing AAA but vehemently denied raping her. He claimed that after a conversation at his porch, he attempted to embrace her and, upon pulling down her shorts, she screamed. Startled, he smashed her head on the floor, resulting in her death. He then hid the body. The Regional Trial Court convicted him of Rape with Homicide and imposed the death penalty. The case was elevated to the Court of Appeals for intermediate review, which affirmed the conviction but modified the penalty to reclusion perpetua without eligibility for parole, pursuant to Republic Act No. 9346.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant committed the special complex crime of Rape with Homicide.

RULING

Yes. The Supreme Court affirmed the conviction. The Court meticulously examined the evidence and found the prosecution’s case to be overwhelming. The accused’s own admission to killing the victim was corroborated by the physical evidence and witness testimonies. The Court rejected the defense of denial of rape, holding that the autopsy findings of genital injuries and hymenal lacerations, coupled with the victim’s discovered state of partial nudity, conclusively proved that sexual assault had occurred. The Court emphasized that rape is consummated by the mere introduction of the male organ into the labia of the female genitalia; full penetration is not required. The superficial nature of the lacerations and the absence of spermatozoa do not negate rape. The killing was established as a direct consequence of the rape, satisfying the elements of the special complex crime. The Court upheld the penalty of reclusion perpetua without parole, as the death penalty could not be imposed due to R.A. No. 9346, and affirmed the awarded damages to the victim’s heirs.