GR 133448; (October, 2000) (Digest)
G.R. Nos. 133448-53; October 6, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSELINDO CUTAMORA and ALLAN CUTAMORA, accused-appellants.
FACTS
Accused-brothers Roselindo and Allan Cutamora were each charged with three counts of rape committed against their nieces, Virginia, Gina, and Beatriz Cutamora, from 1989 to 1993. The victims, who resided with their grandparents and the accused in Agusan del Sur, testified to repeated sexual assaults beginning at very young ages—Virginia at seven, Gina at six, and Beatriz at ten. The acts were committed inside the family home, with each accused threatening the victims to ensure their silence. The defense consisted of alibi and denial, with the brothers claiming they were working on a farm during the alleged incidents, though they gave inconsistent accounts of the farm’s distance from their residence.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellants for three counts of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the convictions. The Court emphasized that the testimonies of the child victims, given in a categorical, straightforward, and convincing manner, were sufficient to establish the crimes of rape. The victims’ young ages and the detailed consistency of their accounts, which withstood rigorous cross-examination, lent strong credibility to their allegations. The Court reiterated that in rape cases, the credibility of the complainant is paramount, especially when she is a minor, as her testimony alone, if credible, can sustain a conviction.
The defense of alibi was rejected as inherently weak and unsubstantiated. For alibi to prosper, the accused must demonstrate not only their presence elsewhere but also the physical impossibility of being at the crime scene. The accused-appellants failed on both counts, providing inconsistent statements about the location of the farm where they allegedly worked. Their denial, uncorroborated by clear and convincing evidence, could not prevail over the positive identification and credible testimonies of the victims, who had no motive to falsely accuse their uncles. Accordingly, the Court upheld the penalties of reclusion perpetua for each count and modified the awards of moral damages to P50,000.00 for each victim, in line with prevailing jurisprudence.