GR 179059; (June, 2012) (Digest)
G.R. No. 179059 ; June 13, 2012
VICTOR RONDINA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
The prosecution alleged that on July 15, 1998, in Ormoc City, petitioner Victor Rondina, armed with a knife, raped the 16-year-old complainant “AAA”. The incident occurred around 4:00 p.m. inside a communal toilet. “AAA” testified that Rondina, a neighbor, suddenly entered, poked a knife at her neck, covered her mouth, threatened to kill her family, and forcibly had carnal knowledge of her. She did not immediately report the rape but disclosed it to her mother months later when a medical examination revealed healed hymenal lacerations and a pregnancy consistent with the alleged date of the assault. She later gave birth to a child.
The defense interposed denial and alibi. Rondina claimed he was at a cockpit in a different barangay from 2:00 p.m. until around 5:30 p.m. on the day in question, attending cockfights with friends. He asserted he could not have been at the crime scene at the time of the alleged incident. The Regional Trial Court found Rondina guilty of rape, a decision affirmed with modification by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of petitioner Victor Rondina for the crime of rape.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of the credibility of witnesses is best undertaken by the trial court. The testimony of “AAA” was found to be credible, straightforward, and consistent on the material points of the rape: force, intimidation, and carnal knowledge. The minor inconsistencies in her narration were deemed inconsequential and even indicative of a truthful, unrehearsed account. The defense of alibi was correctly rejected for being inherently weak and unsubstantiated by clear and convincing evidence. Alibi cannot prevail over the positive identification by the victim, especially where, as here, the accused failed to prove it was physically impossible for him to be at the crime scene at the time of its commission. The medical findings of pregnancy and healed hymenal lacerations corroborated the victim’s claim. The Court also sustained the award of damages, including civil indemnity, moral damages, and exemplary damages, and affirmed the order for Rondina to acknowledge and support the child.