G.R. No. 82121, December 29, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARTURO CRUZ y DE BELEN, defendant-appellant.

FACTS

On December 4, 1986, in Caloocan City, 11-year-old Jackeelyn Eustaquio was washing clothes. On her way home, she was intercepted by the accused-appellant, Arturo Cruz y De Belen. He boxed her, pointed a bladed weapon at her, forced her to lie down, and removed her clothing. The victim testified that the accused placed his penis inside her vagina, causing her pain and bleeding. She managed to escape and report the incident, leading to the appellant’s apprehension by barangay officials, who recovered a knife from him. The victim was medically examined, with a hospital report noting a superficial laceration and abrasion on her vaginal introitus.
The appellant denied the accusation, claiming he was apprehended while eating at a store. He asserted the bladed weapon was a tool for his shoe repair trade, found in his toolbox, not on his person. He contended that the crime of rape was not consummated, citing the testimony of an NBI medico-legal officer who later examined the victim and found her hymen intact, with noted congestions in the vaginal area.

ISSUE

Whether the crime of rape was consummated despite the medical finding of an intact hymen and the absence of complete penetration.

RULING

The Supreme Court affirmed the conviction. The legal logic is anchored on the established doctrine that the crime of rape is consummated by the slightest penetration of the female organ; complete penetration or rupture of the hymen is not required. It is sufficient that there is proof of entrance of the male organ within the labia of the pudendum. The Court found the victim’s testimony—that the appellant placed his penis inside her vagina, causing pain and bleeding—to be credible, straightforward, and corroborated by medical evidence. The initial medical report from Dr. Jose N. Rodriguez Memorial Hospital documented a superficial laceration and abrasion. The subsequent NBI finding of congestion was consistent with these injuries in the process of healing. The appellant, a stranger to the victim, provided no motive for her to falsely testify. Thus, the totality of evidence proved beyond reasonable doubt that rape was committed. The penalty of reclusion perpetua and indemnity were upheld.