G.R. No. 144429 ; July 30, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NORBERTO ORANI Y DULOG, accused-appellant.

FACTS

The accused, Norberto Orani, was charged with the rape of eight-year-old Jenelyn Nuyad on November 27, 1996, in Dupax del Norte, Nueva Vizcaya. The prosecution presented Jenelyn, who testified that while alone in her house at noon, the accused barged in, brought her to a room, covered her mouth, undressed her, and inserted his penis into her vagina, making a pumping motion. He threatened to kill her if she reported the incident. Her mother, Lilia Salvador, upon learning of the rape, brought Jenelyn for medical examination. Dr. Rowena Rosario found no fresh abrasions but noted three old lacerations and reddening, concluding that slight penetration causing trauma was possible.
The defense interposed denial and alibi. Orani claimed he was at the public market selling vegetables with his wife and Lilia until about noon, arriving home at 1:00 PM. He alleged that Lilia fabricated the charge due to a grudge over a denied request to build a house on his family’s land and because he had reported a prior rape incident involving Jenelyn and Lilia’s common-law husband. Defense witness Carmen Acosta corroborated that she, Orani, his wife, and Lilia rode home together at lunchtime, and testified that Lilia later demanded P20,000.00 to withdraw the accusation.

ISSUE

Whether the trial court erred in convicting the accused of rape despite his defense of alibi and denial, and in finding the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The ruling hinged on the credibility of the child victim’s testimony, which was found to be straightforward, candid, and consistent. The Court emphasized that in rape cases, the trial court’s assessment of witness credibility is accorded great respect, and no significant reason existed to overturn it here. Jenelyn’s positive and categorical identification of Orani as her assailant rendered his alibi weak and unavailing. For alibi to prosper, the accused must prove it was physically impossible for him to be at the crime scene. This was not established, as Orani and Jenelyn were neighbors living only meters apart. The alleged grudge was deemed too trivial to motivate a mother to subject her daughter to the ordeal of a false rape charge. The medical findings, while not showing fresh injuries, were consistent with the victim’s account of slight penetration. Consequently, the Court upheld the finding of guilt beyond reasonable doubt for simple rape and the penalty of reclusion perpetua. The civil liability was modified, ordering an additional P50,000.00 in moral damages to the victim.