G.R. No. 172068 - People vs. Mangubat

The case originated in the Regional Trial Court (RTC) of Pinamalayan, Oriental Mindoro, Branch 42, where two separate informations for rape were filed against appellant Rolando Mangubat.
The RTC found Mangubat guilty of qualified rape on two counts, sentencing him to death for each count and ordering indemnification to the victim.
On automatic review due to the imposition of the death penalty, the case was elevated to the Court of Appeals (CA) where it was docketed as CA-G.R. CR.-HC No. 00186, and the CA affirmed the RTC’s decision, though with modifications.
The CA ruled that due to insufficient proof of the relationship qualifying requirement, the crime committed was only simple rape, and accordingly imposed reclusion perpetua for each count, along with orders for civil indemnity and moral damages.
Appellant later filed a Notice of Appeal to the Supreme Court questioning both the conviction and the imposition of the death penalty in the RTC decision.

Two incidences of rape were alleged: one occurring in 1997 and another on June 13, 1998.
The victim, referred to with fictitious initials “AAA” (a minor born in 1987), was at the time just 10–11 years old.
The criminal complaints alleged that Mangubat, with lewd and unchaste design and by means of force and intimidation, sexually assaulted AAA in their house in Barangay Palayan, Pinamalayan, Oriental Mindoro.
The indictments described AAA as the granddaughter of the accused, thereby invoking a special qualifying circumstance to elevate the offense to qualified rape punishable by the death penalty.

The prosecution relied primarily on the detailed and consistent testimony of the victim, AAA.
Testimony from Dra. Adelaida Malaluan, the Municipal Health Officer who conducted a physical examination, corroborated the occurrence of penetration by identifying signs of foreign body penetration and specific hymenal lacerations.
Additional evidence included the testimony of BBB, AAA’s grandmother and the appellant’s common-law wife, who offered corroborative context regarding the victim’s living situation and the alleged incident.
Documentary evidence and stenographic notes complemented the oral testimonies, setting forth the narrative of the incidents in both criminal cases.

Appellant denied the charges, arguing that the allegations were a retaliatory fabrication for a previous act of whipping against AAA.
He asserted that it was physically impossible for such an assault to occur in the confined space of the one-room house given the presence of multiple family members at the time.
The defense sought to downplay the credibility of the victim’s testimony despite her detailed narrative and emotional recounting of the events.

The RTC originally characterized the crime as qualified rape, incorporating the victim’s minority and her alleged relationship with Mangubat (she was described as his granddaughter).
However, both the CA and later the Supreme Court found that while the victim’s minority was sufficiently established, the evidence to prove the specific relationship (by consanguinity or affinity) was lacking.
As a result, the qualifying circumstance necessary to impose the death penalty could not be sustained, and the offense was classified as simple rape.

Whether the evidence presented by the prosecution, principally the victim’s testimony and corroborative medical findings, was sufficient to sustain a conviction for rape beyond reasonable doubt.
Whether the trial court properly appreciated the credibility of the victim’s emotional and detailed recounting of the assaults.
Whether the special qualifying circumstance of relationship (i.e. that the victim was the appellant’s granddaughter by affinity) was proven with the certainty required to impose the higher penalty of death.
Whether appellant’s defenses—namely, his denial of the allegations, provision of an alibi (claiming illness), and his assertion that the allegations were retaliatory—hold any probative value against the overwhelming affirmative evidence.
Whether the trial court’s evaluation of witness credibility and the reliance on the inherent trust accorded to a minor’s consistent testimony were proper given the sensitive nature of the offense.