Title
People vs. Herdez
Case
G.R. No. 23916
Decision Date
Oct 14, 1925
A 70-year-old man convicted of raping his 9-year-old step-granddaughter; Supreme Court ruled minimal penetration suffices for consummated rape, increasing his sentence.

Case Summary (G.R. No. 23916)

Charges and Initial Findings

Domingo Hernandez was charged with the crime of rape, specifically for allegedly engaging in sexual intercourse with Conrada Jocson against her will by threatening her with a knife. The information filed against him outlined aggravating circumstances: his relationship to the victim as the husband of her grandmother and the trust betrayed because they lived in the same household. The gravity of the case stems from the fact that the accused was 70 years old, and the victim was only 9 years old.

Evidence and Testimonies

The evidence presented in court supported a clear narrative of guilt on the part of the defendant. He admitted to having intercourse with the victim but claimed he was intoxicated and unaware of his actions. However, witnesses for the prosecution testified that he exhibited no signs of intoxication during or after the crime. The credibility of the prosecution's case was bolstered by forensic evidence; a physician examined the victim shortly after the incident and found indications of physical injury consistent with non-consensual sexual intercourse.

Legal Interpretation of Rape

The court initially determined that the crime constituted frustrated rape, reasoning that consummated rape required complete penetration of the hymen. This interpretation was at odds with established legal precedents, which clarify that any degree of penetration, even if it does not involve rupture of the hymen, meets the threshold for rape. The court cited several authoritative sources and cases to bolster this perspective, indicating that important distinctions or requirements for penetration are outdated and inconsistent with modern legal understanding.

Final Judgment and Sentencing

Upon reevaluation of the evidence, especially in light of the victim's testimony indicating partial penetration and the medical findings of inflammation and semen, the court concluded that the crime was indeed consummated rape rather than frustrated rape. Given the aggravating circumstances of Hernandez’s relationship to the victim and the breach

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