G.R. No. L-6324 / February 25, 1911
THE UNITED STATES, plaintiff-appellee, vs. JOSE QUEBENGCO, defendant-appellant.

FACTS

The accused, Jose Quebengco, was convicted of the crime of estupro (seduction) by the Court of First Instance of Iloilo. The prosecution’s evidence, primarily from the offended woman, Alejandra Lumanpao, established that Quebengco had persistently tried to have sexual intercourse with her for about a year. She consistently refused unless they were married. To overcome her resistance, Quebengco brought her to his brother, a notary public, who performed a fictitious marriage ceremony on October 27, 1909. A marriage certificate was issued, and based on this deceit, Alejandra consented to sexual relations that night. The accused later retrieved and destroyed the certificate under the pretext of correcting an error. When confronted, Quebengco admitted the deception was necessary because she had refused his advances. The prosecution presented a witness, Eliseo Vencer, who corroborated Alejandra’s account by testifying that he was present and signed as a witness at the ceremony. The defense denied the ceremony ever took place and denied any carnal intercourse, presenting the notary brother and another witness to support the denial.

ISSUE

The sole issue is one of fact: Whose version of events is crediblethe prosecution’s account of a fictitious marriage and subsequent seduction, or the defense’s blanket denial?

RULING

The Supreme Court AFFIRMED the judgment of conviction. The Court deferred to the factual findings and credibility assessment of the trial judge, who had the opportunity to observe the witnesses firsthand. The trial court found the detailed and consistent testimony of the complainant, a simple and uneducated girl, to be credible and unlikely to have been fabricated. The defense’s denial was accordingly rejected. Applying the doctrine established in U.S. v. Ambrosio, the Supreme Court held that it would not disturb the trial court’s conclusions on witness credibility absent a clear showing that material facts were overlooked or misinterpreted. No such error was found in this case. The penalty imposed by the lower court (four months of arresto mayor, accessories, and an indemnity of P500 to the offended woman) was sustained.