G.R. No. 96251 May 11, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANIEL C. NAVARRO, accused-appellant.

FACTS

Accused-appellant Daniel C. Navarro was charged with the rape of his daughter, Angelita Navarro, who was eleven years old at the time of the incident in September 1989. The prosecution presented a Polaroid picture (Exhibit “B”) showing the accused-appellant with his sexual organ inserted into his daughter’s vagina. Angelita testified that her father inserted his erect penis into her private part, causing her pain. Her mother, Elizabeth Cruz Navarro, testified that she took the picture on the accused-appellant’s command while he was having sexual intercourse with their daughter. The accused-appellant waived his right to present evidence. The trial court found him guilty of rape and sentenced him to reclusion perpetua, indemnity, and damages. He appealed the conviction.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.

RULING

Yes. The Supreme Court affirmed the conviction. The prosecution evidence, including the testimonies of the victim and her mother, the medical report showing lacerations on the victim’s hymen, and the Polaroid picture of the sexual act, proved the accused-appellant’s guilt beyond reasonable doubt. The Court rejected the accused-appellant’s argument that his penis was not erect and could not have penetrated, noting that rape is consummated upon the slightest penetration of the labia. The victim’s age (11 years old) was established by her birth certificate, making the crime statutory rape under Article 335(3) of the Revised Penal Code. The Court modified the indemnity, increasing it to P50,000.00 in line with prevailing jurisprudence. The appeal was dismissed for lack of merit.