G.R. No. L-55082. April 19, 1989.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NICANOR DE LOS SANTOS, defendant-appellant.

FACTS

On April 28, 1973, 23-year-old Luzviminda Tan was visiting her aunt in Alcoy, Cebu. That evening, she left to use an outdoor toilet but did not return. Her aunt, Calixta de los Santos, grew worried and, with the help of Jaime Carulasan, searched for her. They were directed to a house where they found Luzviminda lying on the floor, seemingly unconscious, with her dress raised and without her panties. Appellant Nicanor de los Santos was seen nearby, fixing his pants to cover his exposed private organ. Upon seeing them, he turned off the light and fled. The victim was trembling and assisted home.
The following day, a report was filed, and a medical examination on April 30 revealed multiple hematomas and abrasions on Luzviminda’s body. The medico-legal report confirmed the presence of spermatozoa and findings compatible with recent sexual intercourse. A complaint for rape was subsequently filed by Luzviminda’s father, Paulino Tan. The trial court convicted Nicanor de los Santos of rape and sentenced him to reclusion perpetua, acquitting his co-accused. The appellant appealed, contesting the trial court’s jurisdiction.

ISSUE

The primary issue is whether the trial court acquired jurisdiction over the rape case, considering that the complaint was filed by the victim’s father and not by the victim herself, who was of legal age at the time of the incident.

RULING

The Supreme Court affirmed the conviction and upheld the trial court’s jurisdiction. The legal logic centers on the interpretation of Section 4, Rule 110 of the Revised Rules of Court (now Section 5, Rule 110 of the 1985 Rules), which governs the prosecution of crimes like rape. The rule states that such offenses “shall not be prosecuted except upon a complaint filed by the offended party or her parents, grandparents, or guardian.” The provision establishes an exclusive and successive order for who may file the complaint.
The Court ruled that while the offended party holds the preferential right to file the complaint, this presupposes she has the legal and physical capacity to do so. In this case, the evidence demonstrated that Luzviminda was incapacitated. The traumatic experience left her in a state of shock and physical distress, as corroborated by her condition when found and the subsequent medical findings. This incapacity justified her father’s act of filing the complaint on her behalf. The father, as a person expressly authorized by the rules, validly initiated the action, thereby conferring jurisdiction upon the court.
On the merits, the Court found the appellant’s guilt proven beyond reasonable doubt. The credible testimonies of the eyewitnesses, the medico-legal evidence, the appellant’s flight, and the lack of motive for the prosecution witnesses to fabricate the charge all substantiated the conviction. The appeal was dismissed, and the trial court’s decision was affirmed in toto.