G.R. No. 168442 (Formerly G.R. No. 156676) August 30, 2006
People of the Philippines, Plaintiff-Appellee, vs. Oscar Arango y Alegre, Accused-Appellant.

FACTS

The prosecution alleged that on December 25, 2000, in Tinambac, Camarines Sur, accused-appellant Oscar Arango, the godfather (“Ninong”) of the 9-year-old victim Ginalyn Valdez, called her as she passed his house. Under the pretense of asking her to buy rice, he dragged her inside, forcibly undressed her, and succeeded in having carnal knowledge. The victim’s ordeal was interrupted when Hermie Cada, a relative, called from outside the house. Ginalyn seized the chance to escape and immediately reported the rape to Hermie and her mother, leading to a medical examination and police report. The defense presented a starkly different version, claiming Arango was asleep in his house at the time. Defense witnesses testified that the victim was merely playing outside with other children and was later called home by her aunt, Hermie Cada.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of statutory rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. The victim, who was only nine years old at the time of the incident, gave a clear, candid, and consistent account of the rape, which the trial court found credible and worthy of belief. Her testimony was corroborated by the timely revelation of the crime to Hermie Cada and her mother, and by the medical findings. The defense of alibi and denial must fail when arrayed against the positive identification by the credible victim. Alibi is inherently weak and cannot prevail over positive testimony, especially as the defense failed to prove it was physically impossible for the accused to be at the crime scene. The Court also noted that the victim’s minority, established by her birth certificate, transforms the crime into statutory rape under Article 266-A of the Revised Penal Code, where force, intimidation, or lack of consent are immaterial. The elements of carnal knowledge and the victim being below twelve years old were conclusively proven. Thus, the Court upheld the penalty of reclusion perpetua and the awards of civil indemnity and moral damages.