G.R. Nos. 136867-68; September 24, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODRIGO GALVEZ Y JEREZ, accused-appellant.

FACTS

The accused-appellant, Rodrigo Galvez, was charged with two counts of rape for sexually assaulting his daughter, Venus Galvez, then 14 years old. The first incident allegedly occurred on April 30, 1993, and the second on June 30, 1994. The prosecution’s narrative established that the family lived in a one-room house. During the first incident, the victim’s mother was working in Manila. Venus was awakened by her father, who had been drinking, and was later assaulted while she slept. During the second incident, the mother was at a hospital attending to an injured sibling, leaving Venus at home with the accused. He again assaulted her, threatening her not to report the acts. The victim eventually became pregnant, and a medical examination confirmed healed hymenal lacerations and a positive pregnancy test. The accused denied the charges, presenting an alibi that the family was in Manila during the first alleged rape and that the second was impossible due to the family’s focus on his son’s hospitalization.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt, rendering his alibi defense untenable.

RULING

The Supreme Court affirmed the conviction. The Court meticulously analyzed the credibility of the victim’s testimony, which was found to be candid, consistent, and unwavering even under cross-examination. The testimony was corroborated by the medical findings of healed hymenal lacerations and pregnancy, which were consistent with repeated sexual intercourse. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The accused-appellant’s defense of alibi was rejected as inherently weak and unsubstantiated by clear and convincing evidence. The Court noted that 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 accused failed to meet this burden. Furthermore, the relationship between the accused and the victim, being father and daughter, lent credence to the victim’s account, as such a relationship would naturally deter a false accusation due to the associated shame and family dishonor. The trial court’s assessment of witness credibility was accorded great respect. Consequently, the Court upheld the penalties imposed: reclusion perpetua for the first count and, following a review of the records and applicable law at the time, affirmed the death penalty for the second count, which was later commuted to reclusion perpetua pursuant to Republic Act No. 9346 .