G.R. No. 124704 February 22, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LORETO CUADRO y OBEDOZA alias “PIJOK”, accused-appellant.

FACTS

The accused-appellant, Loreto Cuadro, was convicted by the Regional Trial Court on five counts of rape committed against his 12-year-old stepdaughter, Venus Addato. The prosecution’s evidence established that the rapes occurred in May 1992 inside their home in Villasis, Pangasinan, during afternoons when the victim’s mother was away selling corn and her siblings were playing elsewhere. Venus testified that on the first occasion, the appellant, armed with a kitchen knife and intoxicated, forced her to perform oral sex before having carnal knowledge of her, threatening to kill her if she reported the incident. She detailed four subsequent rapes occurring at one-day intervals, some instances also involving a knife, which instilled fear and prevented her resistance. The crime was eventually revealed to the victim’s aunt, Cherry Diaz.
The defense presented denial and alibi. Appellant claimed he and the victim’s mother were engaged in gold panning throughout May 1992, leaving home at 6:00 AM and returning only at 2:00 PM, thus making it impossible for him to be at home during the alleged incidents. This was corroborated by the mother, the victim’s brother, and a neighbor. The defense also argued the victim could not have been raped as no blood was found and that their nipa hut was under repair, making activities inside visible from the outside.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for five counts of rape beyond reasonable doubt, overcoming his defense of alibi and denial.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the young victim’s clear, consistent, and candid testimony prevails over the weak defenses of denial and alibi. The victim’s detailed account of the successive rapes, including the use of a knife and threats on her life, was found to be credible and sufficient to establish the elements of the crime. The Court ruled that alibi is inherently weak and cannot stand against positive identification, especially when the alleged distance does not render physical impossibility. The defense’s claim of visibility from outside the hut was deemed inconsequential, as rapists can commit the crime even in places where they might be seen. The victim’s failure to immediately report due to threats is consistent with the natural behavior of a traumatized child. The medical finding of an old, healed hymenal laceration corroborated her claim of prior sexual abuse. Consequently, the trial court’s decision was upheld, with the modification that the civil indemnity for each count of rape was increased to P50,000.00 in line with prevailing jurisprudence.