G.R. No. 174060 , June 25, 2007
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LITO BEJIC y ANTONI, Accused-Appellant.

FACTS

The accused-appellant, Lito Bejic, was charged with the qualified rape of his 14-year-old daughter, AAA. The prosecution alleged that in the first week of August 2002, inside a relative’s house where the family was temporarily staying, appellant, while his wife and other children were asleep in another room, approached AAA as she slept in the sala. He held her, covered her mouth, removed her clothing, and had carnal knowledge of her against her will. AAA did not immediately report the incident out of fear. Her pregnancy was later discovered in February 2003 by her school principal. After giving birth in May 2003, AAA confessed to her mother, BBB, that appellant was the perpetrator. BBB testified that when confronted, appellant merely bowed his head and cried, and he subsequently left the family.
The defense consisted solely of appellant’s testimony. He denied being present at the house on the alleged date, claiming he stayed at their family residence to tend to their farm and animals, only visiting his family during the day. He asserted he had no knowledge of AAA’s pregnancy when he left to find work, attributing his departure to marital quarrels over money.

ISSUE

Whether the Court of Appeals correctly affirmed appellant’s conviction for qualified rape.

RULING

Yes, the conviction was proper. The Supreme Court affirmed the findings of the lower courts, giving full credence to AAA’s clear, consistent, and candid testimony. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. AAA’s detailed account of the assault, including the use of force and intimidation, and her natural reluctance to immediately disclose the crime due to appellant’s moral ascendancy as her father, were deemed credible and constituted proof beyond reasonable doubt. Her subsequent pregnancy and birth of a child corroborated her claim of sexual intercourse.
The Court found appellant’s defense of alibi weak and unsubstantiated. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to be at the scene. Appellant failed to establish this impossibility, as the distance between the two houses was not insurmountable. His flight after being confronted, and his reaction of bowing his head and crying instead of denying the accusation, were considered evidence of guilt. The qualifying circumstances of minority and relationship were conclusively proven by AAA’s birth certificate and her parents’ marriage contract. However, with the abolition of the death penalty, the penalty was reduced to reclusion perpetua without eligibility for parole.