G.R. No. 172710; October 30, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALBERTO BUBAN, Accused-Appellant.

FACTS

Accused-appellant Alberto Buban was charged with four counts of rape committed against AAA, his wife’s first cousin, on specified dates in 1995 and 1996. The prosecution established that AAA, an orphan, was living with her aunt, EEE, whose daughter was married to Buban. AAA testified that Buban raped her on four occasions inside EEE’s house. She revealed the assaults only in March 1996 after her aunt noticed her bulging stomach. A medical examination confirmed AAA was five to six months pregnant, with the gestation period consistent with the alleged rape dates. AAA’s testimony was corroborated by her aunt and the medico-legal findings.
The defense presented a denial and alibi. Buban claimed he could not have committed the rapes as he was working elsewhere during the alleged dates and had moved to a separate house with his wife by May 1993. He suggested AAA may have been impregnated by a boyfriend, a claim unsupported by evidence. The Regional Trial Court convicted Buban of four counts of rape and sentenced him to reclusion perpetua for each count, awarding moral damages. The Court of Appeals affirmed the conviction but modified the damages by adding civil indemnity.

ISSUE

The core issue is whether the prosecution proved Buban’s guilt for four counts of rape beyond reasonable doubt, overcoming his defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s clear, consistent, and candid narration of the traumatic events, corroborated by her timely complaint to her aunt and the medical evidence of pregnancy, was found credible and sufficient to establish guilt. The Court reiterated that a denial, if unsubstantiated, cannot prevail over positive identification. Buban’s alibi was inherently weak for failing to prove the physical impossibility of his presence at the crime scene, especially since he admitted to frequently visiting the victim’s residence. The defense’s imputation of ill motive on the victim was also rejected for being speculative and lacking factual basis.
Regarding the penalty, the Court sustained reclusion perpetua for each count, as the applicable law at the time of the crimes mandated this penalty for rape. The awards of civil indemnity and moral damages were affirmed, with the Court noting that such awards are automatically granted upon a finding of rape, serving as recognition of the victim’s suffering and as a deterrent. The conviction was thus upheld in its entirety, with the Court finding no reason to deviate from the factual findings and credibility assessments of the lower courts.