G.R. Nos. 142741-43; October 25, 2001
PEOPLE OF THE PHILIPPINES, appellee, vs. ROMEO MANAYAN, appellant.

FACTS

The appellant, Romeo Manayan, was convicted by the Regional Trial Court of Panabo, Davao, for three counts of rape against his niece, Leamarie Pascual, who was 11 years old at the time of the first incident. The Informations alleged that the rapes occurred on April 22, 1994, March 2, 1996, and June 8, 1996, within the house of the victim’s aunt where both the appellant and the victim resided. The prosecution’s version, as presented through Leamarie’s testimony, detailed that the appellant, on each occasion, used force and intimidation to have carnal knowledge of the child, threatening to kill her if she reported the assaults. The incidents were only revealed in June 1996 when the victim confided in her grandfather, leading to a police complaint and a medical examination.
The defense presented a denial and alibi. The appellant claimed he could not have committed the rape on June 8, 1996, as he was allegedly in a different municipality attending a court hearing for another case. He argued that the charges were fabricated due to family resentment, suggesting the complaint was motivated by a prior dispute over land between his brother and the victim’s father. The trial court, however, found the victim’s testimony credible and convicted the appellant.

ISSUE

The core issue for the Supreme Court’s review was whether the trial court erred in convicting the appellant based on the credibility of the victim’s testimony despite alleged inconsistencies and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the testimony of a child victim of rape is accorded great weight. It ruled that minor inconsistencies in the narration of a traumatized child, such as the exact number of times she was kissed or the specific manner of undressing, do not undermine credibility but may instead reflect the natural confusion and naivete of a youthful witness recounting a harrowing experience. The Court found the victim’s categorical and positive identification of the appellant as her assailant to be credible and consistent on the essential fact of sexual violation.
Regarding the defense of alibi, the Court held it to be inherently weak and unavailing against the positive identification by the victim. For alibi to prosper, the defendant must prove not only his presence elsewhere but also the physical impossibility of his being at the scene of the crime. The appellant failed to establish such impossibility, as the location of his alleged court hearing was not so distant as to preclude his presence at the crime scene. The Court also found no ill motive for the young victim to falsely accuse her uncle, reinforcing the reliability of her account. Thus, the trial court’s findings were sustained, and the penalties of reclusion perpetua for each count, along with corresponding damages, were affirmed.