GR 145730; (March, 2002) (Digest)
G.R. No. 145730 March 19, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO ALVARADO, accused-appellant.
FACTS
Accused-appellant Armando Alvarado was charged with the rape of his 14-year-old daughter, Arlene, on July 26, 1997, in Donsol, Sorsogon. The prosecution evidence established that after a drinking spree, the intoxicated appellant went to the room where Arlene was sleeping, removed her clothing, and had carnal knowledge of her. He threatened to kill her and her family if she shouted, compelling her submission. The following day, Arlene experienced pain and bleeding but remained silent out of fear of her violent father.
The crime was revealed a month later when Arlene, working as a housemaid, exhibited distress. Upon learning she was to be sent home, she confided in her employers about the rape. This led to a report to the DSWD, a sworn statement, and a medical examination which revealed a healed laceration. The defense presented denial and alibi, claiming appellant was at a wake 250 meters away during the incident, supported by testimonies from relatives.
ISSUE
Whether the guilt of accused-appellant Armando Alvarado for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed appellant’s conviction but modified the penalty. The Court found the testimony of the victim, Arlene, to be credible, straightforward, and consistent. Her detailed account of the sexual assault and the threat that subdued her resistance was deemed sufficient to establish the elements of rape. The medical finding of a healed laceration corroborated her claim of penetration. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of alibi was rejected as inherently weak and unsubstantiated. For alibi to prosper, the accused must demonstrate it was physically impossible for him to be at the crime scene. The Court found it not only possible but probable for appellant to have been at his home, a mere 250 meters from the wake, to commit the crime. The testimonies of defense witnesses, being close relatives, were considered biased and insufficient to overthrow the positive identification by the victim. The qualifying circumstance of relationship was duly proven, warranting the imposition of reclusion perpetua instead of the death penalty, in line with prevailing jurisprudence at the time. The Court affirmed the award of moral damages and civil indemnity and added exemplary damages.