G.R. Nos. L-79369-70 October 28, 1988
People of the Philippines, plaintiff-appellee, vs. Alexander A. Quidilla, defendant-appellant.

FACTS

The accused-appellant, Alexander A. Quidilla, was charged with two counts of rape committed against Yaniza Sena, an 11-year-old minor, in the second and third weeks of March 1985 in Laoag City. The complaints were identically worded except for the dates. After a joint trial where the accused pleaded not guilty, the Regional Trial Court found him guilty beyond reasonable doubt of both charges. He was sentenced to suffer the penalty of reclusion perpetua for each case, to be served successively, and ordered to pay moral damages. The appellant appealed, contending the trial court erred in convicting him for two counts of rape instead of acts of lasciviousness for the first incident and acquittal for the second.
The prosecution’s case rested primarily on the testimony of the young victim. For the first incident (Criminal Case No. 2856), she testified that the appellant pulled her into a men’s room, covered her mouth, forced her to lie down, removed her panties, and succeeded in having carnal knowledge with her despite her struggles, which caused her pain. For the second incident (Criminal Case No. 2855), she narrated that the appellant again brought her to the same room, threatened her with a knife, and raped her. The defense presented a different version. For the first incident, the appellant claimed he merely touched the victim’s private parts over her clothing. For the second, he interposed an alibi, asserting he was in a different barangay at the time.

ISSUE

The core issue is whether the trial court correctly convicted the appellant of two counts of rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court affirmed the conviction. The ruling emphasized that in rape cases where the testimonies of the victim and the accused are diametrically opposed, the outcome hinges on credibility. The Court found no reason to deviate from the trial court’s factual findings, which are accorded great weight and respect on appeal, especially as no facts of substance were overlooked. The victim’s detailed, candid, and consistent narration of both incidents, including the use of force and intimidation, was found credible and sufficient to establish the crime of rape beyond reasonable doubt.
The Court rejected the appellant’s alternative claim for the first incident. His admission to touching the victim’s private parts, coupled with the victim’s clear account of sexual intercourse, constituted rape, not merely acts of lasciviousness. His defense of alibi for the second incident was likewise unavailing. Alibi cannot prevail over the victim’s positive identification, especially when it was not physically impossible for him to be at the crime scene; the distance of eight kilometers between locations did not preclude his presence. Furthermore, the victim’s minority (11 years old) rendered any alleged consent legally irrelevant. The Court noted the receptivity to lending credence to the testimony of young victims, given their vulnerability and the ordeal of a public trial. The appealed decision was affirmed in toto.