G.R. No. 182789 ; August 3, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. NORLITO SAMBAHON Y NUEVA, Appellant.

FACTS

The appellant, Norlito Sambahon, was convicted of qualified rape against his 13-year-old stepdaughter, AAA. The prosecution established that on the evening of August 12, 2003, in their home in Tinambac, Camarines Sur, appellant returned to the house while his wife was away. He approached the sleeping AAA, tied her hands, removed her clothing, and had carnal knowledge of her against her will, threatening to kill her family if she reported the incident. The crime was discovered months later when AAA was found to be pregnant during a medical check-up. A medical examination confirmed old hymenal lacerations consistent with sexual intercourse.
During pre-trial, appellant admitted AAA was his stepdaughter and that she was 13 years old at the time of the incident. At trial, he interposed the defense of alibi, claiming he was at a drinking session elsewhere during the alleged rape. The Regional Trial Court found him guilty and imposed the death penalty, which the Court of Appeals modified to reclusion perpetua in line with Republic Act No. 9346 , while affirming the conviction.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for qualified rape based on the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence.

RULING

The Supreme Court affirmed the conviction. The Court held that the victim’s testimony was credible, consistent, and sufficient to establish the crime of rape. Minor inconsistencies between her sworn statement and court testimony regarding the specific room where the rape occurred were deemed inconsequential and did not affect her core narrative of the sexual assault. The Court emphasized that testimonies of child-victims of rape are given full weight and credit, as youth and immaturity generally deter them from fabricating such grave accusations.
The defense of alibi was correctly rejected for being weak and unsubstantiated, especially as appellant failed to prove it was physically impossible for him to be at the crime scene. His relationship as a stepfather constituted a qualifying circumstance under Article 266-B of the Revised Penal Code, warranting the penalty of reclusion perpetua without eligibility for parole. The Court found all elements of qualified rape present: carnal knowledge through force or intimidation, with the victim under eighteen and the offender a step-parent. The affirmed damages awarded were civil indemnity, moral damages, and exemplary damages.