G.R. No. 134772; June 22, 2000
People of the Philippines, plaintiff-appellee, vs. Felipe Hofileña y Taala, accused-appellant.

FACTS

The accused-appellant, Felipe Hofileña, was convicted by the Regional Trial Court of Malaybalay, Bukidnon, for the rape of Iries Ente, a 12-year-old student. The prosecution established that on November 9, 1996, Hofileña, the overseer of the boarding house where Ente stayed, entered her room while she was alone. Armed with a dagger, he threatened to kill her if she made noise, forced her onto a bed, and had sexual intercourse with her against her will. The victim, in pain and bleeding, did not immediately report the incident due to fear of the accused’s threats against her and her parents. The crime was only revealed weeks later when her mother, concerned over her school absences and pallor, brought her to a hospital.
The defense interposed alibi and denial. Hofileña claimed he was at his workplace, Victorias Milling Company, six kilometers away, during the alleged rape. He presented a corroborating witness, Clarita Cosme, who testified she was at his house visiting his wife during the relevant hours and did not see him there. The trial court rejected this defense, finding the victim’s testimony credible and noting the lack of ill motive for her to falsely accuse a married man.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the victim’s testimony and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the well-entrenched principle that the trial court’s assessment of witness credibility is accorded the highest respect, as it is in the best position to observe demeanor and sincerity. The Court found no reason to deviate from the trial court’s conclusion that the victim’s detailed, candid, and consistent narration of the traumatic event was credible and worthy of belief. Her testimony alone, if credible, is sufficient to sustain a conviction for rape.
The defense of alibi was correctly dismissed for being inherently weak and unpersuasive. For alibi to prosper, the accused must demonstrate not only that he was elsewhere when the crime occurred but that it was physically impossible for him to have been at the scene. The Court found that the distance of six kilometers between his workplace and the crime scene did not constitute such physical impossibility. The corroborating testimony was deemed insufficient to overthrow the positive identification by the victim. The Court upheld the penalties imposed, including reclusion perpetua and indemnities, and additionally awarded moral damages to the victim.