G.R. No. L-37791 October 30, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CESARIO SALAZAR, defendant-appellant.

FACTS

Cesario Salazar was convicted by the Court of First Instance of Misamis Oriental for the rape of thirteen-year-old Mercedes Macahilos on September 17, 1972, in Barrio Ricoro, Gingoog City. He was sentenced to life imprisonment, indemnity, and costs. Salazar appealed, raising four errors. Primarily, he argued the trial court lacked jurisdiction due to an invalid complaint, contending it was not properly subscribed and sworn to by the complainant as required by the Rules of Court. He cited People vs. Santos to support his claim that the document was merely an information filed by the fiscal, not a valid complaint from the offended party.
The prosecution’s evidence established that on the night in question, Salazar, armed with a dagger, forced Mercedes from her house to a pineapple plantation and raped her. Her testimony was corroborated by her aunt, Norma Batulan. The defense presented an alibi, with witnesses testifying Salazar was drunk and brought home that night. The trial court found the complainant’s positive identification credible and rejected the alibi, noting the defense witnesses could not account for Salazar’s whereabouts after they went to sleep.

ISSUE

The core issues were: (1) whether the trial court acquired jurisdiction via a valid complaint, and (2) whether the evidence was sufficient to prove guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty to death. On jurisdiction, the Court ruled the complaint was valid. It was a sworn written statement explicitly commencing with “The undersigned, Mercedes Macahilos herein Offended Party, after having been duly sworn, accuses…” This constituted substantial compliance with Rule 110. The cited Santos case was distinguishable as it involved an information filed solely by the fiscal where the offended party did not participate. Here, the complainant herself was the accuser, and her oath was incorporated into the document’s opening paragraph, satisfying the jurisdictional requirement.
On the merits, the Court found the evidence sufficient. The complainant’s clear and positive testimony, corroborated by her aunt, prevailed over the weak alibi. The defense witnesses only established Salazar’s intoxication and return home but could not confirm his presence there at the exact time of the crime, as they had gone to sleep. The commission of rape with a deadly weapon (a dagger) under Article 335 of the Revised Penal Code, as amended by R.A. 4111, warranted the penalty of reclusion perpetua to death. With two aggravating circumstances—nighttime and dwelling of the offended party—present, the Supreme Court imposed the supreme penalty of death. The indemnity was increased to P12,000.