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 the house of Gildo Egon. Upon entering, they found Luzviminda seemingly unconscious on a floor, her dress raised and without underwear. Appellant Nicanor de los Santos was beside her, fixing his pants with his private organ still exposed. 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 bruises 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 the victim’s father, Paulino Tan. The trial court convicted Nicanor de los Santos of rape and sentenced him to reclusion perpetua, while acquitting his co-accused. The appellant appealed, contesting the trial court’s jurisdiction.

ISSUE

Did the trial court acquire jurisdiction over the rape case despite the complaint being filed by the victim’s father and not by the victim herself, who was of legal age at the time of the incident?

RULING

Yes, the trial court validly acquired jurisdiction. The Supreme Court affirmed the conviction. Appellant argued that under Section 4, Rule 110 of the Revised Rules of Court, a complaint for rape must be filed by the offended party herself if she is of legal age, and thus the complaint filed by her father was jurisdictionally defective. The Court clarified that the rule grants a successive and exclusive right to institute the action to the offended party, her parents, grandparents, or guardian, in that order. However, this preferential right of the victim assumes she has the legal and physical capacity to file the complaint herself.
The Court upheld the trial court’s finding that Luzviminda was incapacitated from filing the complaint. The records showed she was not in complete possession of her mental and physical faculties following the traumatic incident, as evidenced by her state when found and her condition thereafter. This incapacity justified her father’s act of filing the complaint on her behalf. Therefore, the complaint was valid and conferred jurisdiction upon the trial court.
On the merits, the Court found the appellant’s guilt proven beyond reasonable doubt. The credible testimonies of the eyewitnesses, the medical evidence corroborating forcible intercourse, and the appellant’s own conduct (fleeing upon discovery) collectively established his culpability. The Court found no ill motive for the witnesses to falsely accuse him. The penalty of reclusion perpetua and the indemnity awarded were thus affirmed.