GR 169870; (August, 2009) (Digest)
G.R. No. 169870; August 4, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. ELEGIO AN, Appellant.
FACTS
On March 8, 1998, Conchita Maranan, a 21-year-old woman with no formal education, was raped by appellant Elegio An. After taking a bath in the river, she saw appellant enter her relative’s house. When she followed, appellant pushed her into a room, undressed her, and forcibly had carnal knowledge with her. After the act, appellant threatened to kill her if she reported the incident. Conchita immediately went to her sister, Zenaida Andallon, crying and in pain. She eventually confided that she was “inasawa” by appellant, describing the sexual assault. Zenaida found Conchita’s bloodied underwear and observed bleeding in her vagina. They reported the crime to barangay officials, leading to appellant’s apprehension.
The following day, a medical examination revealed spermatozoa in Conchita’s vagina and multiple lacerations, corroborating the rape. An Information was filed against appellant. During trial, the prosecution presented Conchita’s credible testimony and medical evidence. The defense presented denial and alibi, claiming appellant was at a baptismal celebration in another barangay at the time of the incident. The Regional Trial Court found appellant guilty of simple rape and sentenced him to reclusion perpetua, which the Court of Appeals affirmed.
ISSUE
Whether the Court of Appeals correctly affirmed appellant’s conviction for the crime of simple rape.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, emphasizing that the credibility of the victim’s testimony is paramount in rape cases. Conchita’s straightforward and consistent narration of the forcible sexual intercourse, corroborated by her immediate outcry to her sister, the physical evidence of her bloodied underwear and bleeding, and the medico-legal findings proving spermatozoa and lacerations, collectively established the crime beyond reasonable doubt. The Court found her testimony credible, natural, and convincing.
Appellant’s defense of denial and alibi was correctly rejected. For alibi to prosper, the accused must prove not only his presence elsewhere but also the physical impossibility of being at the crime scene. Appellant failed to establish this impossibility, as the location of the baptismal celebration was not so distant as to preclude his presence at the crime. Denial, being inherently weak, cannot prevail over the positive identification and credible testimony of the victim. The affirmed penalty is reclusion perpetua, with corresponding civil indemnity and moral damages.
