G.R. No. L-44412 November 25, 1983
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME SAMBANGAN y VELASQUEZ, defendant-appellant.

FACTS

The accused, Jaime Sambangan, was convicted of rape by the Court of First Instance of Rizal and sentenced to reclusion perpetua. The information alleged that on April 27, 1975, in Caloocan City, he had sexual intercourse with Maria Theresa Manguera, a nine-year-old minor. The prosecution evidence established that Sambangan, who was acquainted with the victim’s family, brought the child into a bodega within their residential compound. There, he ordered her to undress, removed his own pants, and lay on top of her. The victim’s mother discovered them exiting the bodega and later noticed a whitish substance on her daughter’s panty. The child disclosed the assault. A medical examination revealed a healed hymenal laceration, indicating partial penetration.
The defense consisted of a denial and an alibi. Sambangan claimed he did not remember any unusual event on that date and denied seeing the victim. He also suggested the complaint was fabricated due to a prior estrangement with the victim’s father over a romantic affair. He further challenged the admissibility of a sworn confession, alleging coercion.

ISSUE

The core issue is whether the prosecution proved the crime of rape beyond reasonable doubt, overcoming the defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic proceeds from the statutory definition of rape under Article 335 of the Revised Penal Code. Carnal knowledge of a girl under twelve years constitutes rape, irrespective of force or intimidation. The gravamen is the carnal knowledge itself. The Court found the testimonies of the nine-year-old victim, her mother, and the medico-legal officer credible and consistent. The medical finding of a hymenal laceration corroborated the fact of sexual abuse, even if penetration was only partial, as complete penetration is not required for the crime to be consummated.
The defenses were rejected. Denial is inherently weak against positive identification. The alibi failed because Sambangan did not prove it was physically impossible for him to be at the crime scene. The motive of revenge alleged by the defense was deemed unconvincing; the Court found it improbable that a father would subject his young daughter to the ordeal of a public trial based on a false accusation. The Court also dismissed the argument about the victim’s lack of outcry, as force or intimidation is not an element when the victim is below twelve. The sworn confession, while discussed, was not ultimately essential to the affirmance, as the other evidence sufficed to establish guilt beyond reasonable doubt.