G.R. No. 187744 ; June 20, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROGER TEJERO, Accused-Appellant.

FACTS

Accused-appellant Roger Tejero was charged with three counts of rape committed against his 14-year-old stepdaughter, AAA, on February 1, February 8, and April 4, 2004. The prosecution presented AAA’s testimony that Tejero, who was cohabiting with her mother, raped her on these dates in their home, using force, intimidation, and threats to kill her family if she reported the incidents. Her pregnancy, discovered during a medical check-up, was presented as a result of the rapes. Her birth certificate proved her minority. The defense consisted solely of Tejero’s denial and alibi. He claimed he could not have committed the rapes as all alleged dates fell on a Sunday, when he was working as a jeepney driver, waiting for passengers in Bangued, Abra, during the times of the incidents.
The Regional Trial Court convicted Tejero of three counts of rape, sentencing him to reclusion perpetua for each count and awarding moral damages. The Court of Appeals affirmed the conviction but modified the damages by adding civil indemnity. Tejero appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi should prevail over AAA’s testimony.

ISSUE

Whether the Court of Appeals erred in affirming Tejero’s conviction for three counts of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim-witness is paramount in rape cases. AAA’s categorical, consistent, and straightforward testimony, detailing the incidents of sexual assault and the threats made by her stepfather, was found credible and sufficient to establish guilt beyond reasonable doubt. The Court ruled that her testimony alone, if credible, is enough to sustain a conviction for rape.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to be at the scene. Tejero failed to meet this burden. His claim of being at a jeepney parking area did not constitute physical impossibility, as the distance between that location and the crime scene was not insurmountable. His denial, being inherently weak, could not prevail over the positive identification and credible testimony of the victim. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages, consistent with prevailing jurisprudence.