G.R. No. 137454 - People vs. Cantuba y Deblois

On June 10, 1997, at 4:00 o’clock in the afternoon, Belinda Lampas arrived home from work and found her five-year-old daughter, Jennifer, limping and holding her private part.
Jennifer, upon being questioned by her mother, disclosed that their neighbor, known as “Kuya Jerry,” had taken her to his sister’s house where he undressed her and molested her by inserting his erect penis into her vagina.

Jennifer’s bloodied undergarments (panty, dress, and shorts) were later presented by the prosecution as evidence.
On the same afternoon of the incident, Belinda, accompanied by a neighbor’s daughter, sought help from the local authorities at Camp Crame.
During a medical examination conducted by Dr. Manuel Reyes:

The doctor observed a congested vestibule, posterior fourchette, and an elastic, fleshy, and congested hymen with deep fresh lacerations at the 2 and 10 o’clock positions.
He noted that the external vaginal orifice admitted the tip of his smallest finger, findings consistent with forcible insertion of a hard blunt object (i.e., an erect penis), and evidence of recent loss of virginity.

Later on the evening of June 10, 1997, Belinda sought assistance from Dominador, a BSDO in Balara, who arrested the accused, Jerry Cantuba y Deblois, and brought him to Precinct 6 in Old Balara, Quezon City.
Jennifer filed a complaint against the accused, charging him with rape before the Quezon City Regional Trial Court (RTC).
The charges included that the accused, using force and intimidation, unlawfully and feloniously undressed and then had carnal knowledge with a minor against her will and without her consent.

Belinda Lampas testified regarding the discovery of Jennifer’s condition and the subsequent medical examination.
Dr. Manuel Reyes provided a detailed account of his findings, which confirmed forensic evidence of rape.
Jennifer, despite her young age and trauma, testified in court corroborating her account that it was the accused who abused her.
Clinical psychologist Elvira Valismo testified that Jennifer suffered from depression and trauma following the incident.

Jerry Cantuba y Deblois testified that he was engaged in work-related activities and later watched television with his neighbor, Avelino Magno, at the house of Zaldy Salas.
Magno corroborated part of the accused’s narrative by stating that he went home around 4:00 pm while the accused proceeded to another house.
The defense advanced a theory of mistaken identity, suggesting that another individual known as Jerry Teves (later identified as Jerry Obregona) could be the true perpetrator.

Joffrey Cantuba, the accused’s brother, and his wife Celestina gave statements that conflicted with the accused’s version regarding his whereabouts.
Other witnesses, including Edna Bianes, testified to dismiss the alleged presence of the accused at the scene during the critical time period.
On direct examination and rebuttal, Jennifer consistently identified Jerry Cantuba y Deblois as her abuser, dismissing the possibility of mistaken identity.

The Quezon City RTC, on January 13, 1999, rendered judgment finding the accused guilty of rape beyond reasonable doubt.
The initial sentence imposed the death penalty, along with an order to indemnify the victim with P50,000.00 as moral damages and additional costs.
The accused later argued errors in the trial court’s findings and in the imposition of the death penalty.

Finding him guilty beyond reasonable doubt based primarily on the victim’s testimony and available physical evidence.
Imposing the death penalty even if proven guilty, particularly on the grounds that the victim’s age was not definitively established as a qualifying factor for the death penalty under the law.

The appellate scrutiny involved issues of testimonial credibility, alibi strength, and the evidentiary standard required to establish the victim’s age, which affects the qualification of the crime.

Whether the trial court erred in finding the accused guilty beyond reasonable doubt of rape, given the conflicting testimonies regarding his alibi and the allegation of mistaken identity.
Whether the trial court's imposition of the death penalty was proper, specifically in light of the uncertainty surrounding the victim’s age and the corresponding qualifying circumstances for the capital offense.
Whether the evidence presented, particularly the victim’s identification and the physical and medical findings, sufficiently established the crime of rape and met the burden of proof required for such a conviction.