G.R. No. 181081; September 4, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROLDAN ARCOSIBA alias “Entoy,” Accused-Appellant.

FACTS

The prosecution established that on March 21, 2004, the 14-year-old victim, AAA, and her friend BBB were at AAA’s house when accused-appellant Roldan Arcosiba arrived. Arcosiba, invoking a debt owed by AAA’s father, commanded AAA to go outside. Through force, threats, and intimidation, including a threat to shoot her, Arcosiba made AAA undress, ordered her to masturbate him, and then proceeded to have carnal knowledge of her. The act was interrupted by the arrival of neighbors alerted by BBB. Arcosiba fled when a neighbor shouted at him. AAA reported the incident and underwent a medical examination the next day, which revealed old healed hymenal lacerations and erythema on her labia.
Arcosiba denied the accusation, proffering an alibi. He claimed he was at his live-in partner’s parents’ house and later engaged in a drinking spree with friends during the time of the alleged incident. The Regional Trial Court convicted him of rape under Article 266-A of the Revised Penal Code, as amended, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Roldan Arcosiba’s conviction for the crime of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the factual findings of the trial court, emphasizing that the victim’s categorical, consistent, and credible testimony prevails over the accused’s bare denial and alibi. The Court reiterated the doctrine that when the victim’s testimony is credible, it is sufficient to sustain a conviction for rape. The medical findings, while noting only old hymenal lacerations, were consistent with the victim’s account, as the absence of fresh injuries does not negate rape, especially given the victim’s young age and the use of intimidation. The erythema or redness found supported the claim of recent sexual contact.
The legal logic is anchored on the principle that denial and alibi are inherently weak defenses which cannot prevail over positive identification by a credible witness. For alibi to prosper, the accused must demonstrate not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the scene. Arcosiba failed to prove such impossibility. Moreover, the victim’s straightforward narration of a harrowing experience, coupled with her immediate report and submission to physical examination, carries the hallmarks of truth. The Court found no ill motive for the young victim to falsely accuse the appellant and endure the ordeal of a public trial. Thus, the prosecution successfully proved the elements of rape through force and intimidation beyond reasonable doubt.