GR 170840; (November, 2006) (Digest)
G.R. No. 170840 ; November 29, 2006
THE PEOPLE OF THE PHILIPPINES, Appellee, vs. GREGORIO CARPIO @ “GORIO,” Appellant.
FACTS
Appellant Gregorio Carpio was charged with two counts of statutory rape committed against AAA, the minor daughter of his wife’s relative. The first incident allegedly occurred in 1991 when AAA was nine years old, and the second transpired between June and August 1993. The prosecution established that AAA, then living near the appellant, was repeatedly assaulted. The abuse was discovered in December 1993 when BBB, AAA’s mother, learned from a neighbor about seeing appellant with AAA in a compromising situation. Confronted, AAA disclosed the rapes. A medical examination revealed old hymenal lacerations consistent with sexual intercourse.
The defense presented denial and alibi. Appellant claimed AAA was living elsewhere during the alleged periods and presented witnesses, including cockpit managers, to attest he was working as a sentenciador during the times of the incidents. He argued the charges were fabricated due to a family dispute over BBB’s refusal to let the appellant and his wife adopt AAA.
ISSUE
The core issue is whether the prosecution proved the guilt of the appellant for two counts of statutory rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the appellant’s conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s candid, consistent, and unwavering narration of the traumatic events, corroborated by the medical findings of old hymenal lacerations, constituted proof beyond reasonable doubt. The Court found her testimony credible, noting that her initial silence and fear were natural reactions for a child victim.
The defense of alibi and denial was rejected. Alibi is inherently weak and must be established with clear and convincing evidence that the accused was physically impossible to be at the crime scene. The appellant failed to prove this impossibility. His presented certifications of cockpit employment did not conclusively place him elsewhere at the specific times of the rapes. The Court also found the alleged motive for fabrication—the adoption dispute—insufficient to overturn the positive identification and credible testimony of the victim. The affirmance modified the awards of damages in accordance with prevailing jurisprudence.