GR 126169; (December, 1999) (Digest)
G.R. No. 126169 December 21, 1999
People of the Philippines vs. Apolinario Geromo
FACTS
The prosecution established that on May 20, 1992, in Guihulngan, Negros Oriental, accused-appellant Apolinario Geromo, armed with a hunting knife, raped his thirteen-year-old stepdaughter, Marlyn Calago, five times inside their home while her mother was away and her younger siblings slept. Marlyn did not immediately report the rape due to death threats from Geromo. The crime was only revealed in December 1992 when Marlyn, suffering from a hemorrhage due to an involuntary abortion, confessed to her mother that Geromo was responsible for her pregnancy.
Geromo pleaded not guilty and interposed the defense of alibi, claiming he was in Cebu City seeking employment on the date of the incident and only returned in April 1993. He suggested the charge was fabricated due to a marital dispute with his wife, Crispina, over insufficient financial support. The trial court found the prosecution’s evidence credible and convicted Geromo of rape, sentencing him to reclusion perpetua and ordering him to pay moral damages.
ISSUE
Whether the trial court erred in convicting Geromo of rape based on the lone, uncorroborated testimony of the victim, despite his defense of alibi and alleged inconsistencies.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. Marlyn’s detailed and candid account, given by a young barrio girl, was found credible and consistent with human nature and experience. The Court reiterated the doctrine that a young and decent Filipina would not concoct a story of defilement, expose herself to public scrutiny, and allow the imprisonment of a family member unless motivated by truth.
Geromo’s alibi was correctly rejected for being inherently weak and unsubstantiated. His claim of being in Cebu was belied by his own admission that he was in Guihulngan to vote in the May 1992 elections. Alibi cannot prevail over the positive identification by the victim. The Court also noted that the defense failed to prove any ill motive for the victim and her mother to falsely accuse him. The award of moral damages was sustained, and civil indemnity of P50,000 was additionally awarded to the victim, in line with prevailing jurisprudence.