G.R. No. 124393 ; January 31, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO SANCHEZ @ Rudy, accused-appellant.

FACTS

The accused-appellant, Rodolfo Sanchez, was convicted by the Regional Trial Court of thirty-three counts of rape against his 14-year-old stepdaughter, Jeany Sanchez. The informations alleged that the rapes occurred on specified Saturdays from February 6 to October 2, 1993, in San Manuel, Pangasinan. Jeany testified that the accused, using a knife, force, and intimidation, sexually assaulted her whenever her mother left the house to sell fish. She initially remained silent due to death threats but eventually reported the incidents to her aunt and the police in October 1993. Medical examination revealed old hymenal lacerations consistent with sexual intercourse.
The defense presented denial and alibi, claiming the accused was working as a carpenter in Burgos, Ilocos Sur, from January to April 1993 and was employed locally thereafter, leaving home early and returning late, including Saturdays. The accused and his wife, Lilia (Jeany’s mother), testified to this effect, with Lilia initially stating the accused was home on March 6 but later changing her testimony. On rebuttal, Jeany maintained the accused was jobless during the initial period and did not work on Saturdays, asserting the rapes occurred as alleged.

ISSUE

Whether the guilt of the accused-appellant for thirty-three counts of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Jeany Sanchez, to be credible, straightforward, and consistent even under rigorous cross-examination. The defense of alibi and denial was inherently weak and could not prevail over her positive identification. The Court noted that for alibi to succeed, the accused must demonstrate it was physically impossible for him to be at the scene of the crime. The accused failed to do so; his claimed work locations were not so distant as to preclude his presence at the crime scene on the specified Saturday mornings. Furthermore, the testimonies of the accused and his wife were inconsistent regarding his whereabouts on key dates, damaging their credibility. The medical findings corroborated Jeany’s account of sexual abuse. The Court also emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The trial court’s assessment of witness credibility is accorded high respect. Thus, the prosecution successfully established all elements of rape through force and intimidation for each of the thirty-three counts beyond reasonable doubt. The penalties and awards of moral damages were affirmed.