GR 125910; (May, 1998) (Digest)
G.R. No. 125910 May 21, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EFREN CABEBE, accused-appellant.
FACTS
The accused-appellant, Efren Cabebe, was charged with the rape of Ednalyn Daboc, his 13-year-old stepdaughter, sometime in May 1993 in Barangay Guadalupe, Coron, Palawan. The prosecution’s version, as presented through the victim’s testimony, stated that while the victim’s grandmother was away and her mother was in town, Cabebe called Ednalyn to pick lice from his head. While she was doing so, he undressed her, forcibly laid her down, removed his clothes, and had carnal knowledge of her against her will and consent. The victim cried in pain and saw blood, but did not shout due to fear. The incident was later revealed to her aunt and grandmother. A medical examination showed an abrasion at her vaginal orifice. The defense presented Cabebe’s denial and alibi, claiming he was at work, about 2.5 kilometers away, at the time of the alleged incident. The trial court convicted Cabebe, giving credence to the victim’s clear and coherent testimony and noting a letter he wrote asking for forgiveness, which was considered an implied admission of guilt.
ISSUE
Whether the trial court erred in convicting the accused-appellant of rape based on the credibility of the victim’s testimony and in rejecting his defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court held that the trial court’s assessment of the credibility of witnesses, particularly the rape victim, deserves the highest respect absent any showing of oversight or misapprehension of facts. The victim’s testimony was straightforward, candid, and sufficient to establish guilt. The Court found no improper motive for the victim to falsely accuse the appellant. The defense of alibi was properly rejected as it was not physically impossible for the appellant to have been at the scene of the crime, and such a defense is inherently weak. The appellant’s letter asking for forgiveness from the victim’s grandmother was considered a tacit admission of culpability. The penalty of reclusion perpetua was affirmed, and the civil indemnity of P50,000 was also upheld.