G.R. No. 133480 ; March 15, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FLORANTE AGUILUZ Y NUQUE, accused-appellant.

FACTS

The accused-appellant, Florante Aguiluz, was charged with the rape of his grandniece, Elizabeth Cruz, a girl below twelve years of age, on October 15, 1995, in Calumpit, Bulacan. The prosecution’s evidence established that on said date, Elizabeth was watching television at the accused’s house. Upon returning to her own adjacent house, she found the accused alone inside. He dragged her to a room, removed her clothing, and had carnal knowledge of her despite her resistance. Threatened with death if she reported the incident, Elizabeth initially remained silent but later confided in her teacher, leading to a medical examination and the filing of a complaint.
The medico-legal report confirmed deep, healed lacerations on Elizabeth’s hymen, which the examining physician testified could have been caused by sexual intercourse. In his defense, Aguiluz denied the accusation and interposed an alibi, claiming he was serving as a lay minister at a church during the time of the alleged crime. However, his corroborating witness, a priest, testified that there was only a morning mass on that day, undermining the alibi.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of statutory rape.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in cases of statutory rape under Article 335(3) of the Revised Penal Code, as amended, the sole factual issue is whether the accused had carnal knowledge of a woman below twelve years of age. The complainant’s age, proven by her Certificate of Live Birth, was not disputed. Her credible and categorical testimony on the sexual act was sufficient to establish the crime. The medical findings, while not showing fresh injuries, corroborated her account, as healed lacerations were consistent with recent penetration. The Court found no material inconsistency in her narration.
The defense of alibi was rightly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. The accused failed to do so, as the church was not so distant as to preclude his presence at the locus criminis. The positive identification by the victim, who knew him well as a relative, prevailed over his weak denial. Consequently, the penalty of reclusion perpetua was proper. The Court affirmed the award of P50,000.00 as moral damages and additionally awarded P50,000.00 as civil indemnity.