GR 110808; (May, 1995) (Digest)
G.R. No. 110808 May 31, 1995
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFONSO QUINEVISTA, JR., accused-appellant.
FACTS
On the evening of December 1, 1991, 15-year-old Amelia Torres was at home in Poloy-Poloy, Lebak, Sultan Kudarat, with her sleeping siblings. The door was unlocked. Appellant Alfonso Quinevista, Jr., a neighbor and brother of her former sweetheart, entered the house. He was clad only in underwear and brandished a knife. He threatened to kill her if she refused, put out the kerosene lamp, undressed her, and forcibly had carnal knowledge of her. Afterward, he warned her not to tell anyone.
When her father arrived later that evening, he found her weeping. She revealed the rape. She was immediately brought for investigation, and a team was dispatched to arrest appellant. The apprehending team testified that blood was found on appellant’s underwear and the tip of his penis. A medical examination of the complainant that same night revealed fresh hymenal lacerations consistent with forcible penetration.
ISSUE
Whether the trial court erred in convicting appellant of rape based on the credibility of the complainant’s testimony and in disregarding the defense of alibi and denial.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, which it found to be candid and straightforward. Her positive identification of appellant was deemed reliable, as the illumination from a kerosene lamp was sufficient for recognition. Her testimony was corroborated by the medical findings of fresh hymenal lacerations and the immediate report of the crime to her father and authorities. The Court emphasized that it is inconceivable for a young Filipina from a rural area to fabricate a story of rape, an act that brings social stigma, unless it were true.
The defense of alibi and denial was rejected. Appellant failed to prove it was physically impossible for him to be at the crime scene, as the distance between his house and the victim’s was easily negotiable. The testimony of his brother, Dante, claiming he was the one who had consensual sex with the complainant that night, was found to be a mere fabrication to exculpate appellant. Testimonies from immediate relatives are inherently suspect. Alibi, especially when uncorroborated by disinterested witnesses, is the weakest defense. The elements of rape through force and intimidation were proven beyond reasonable doubt.