GR 177749; (December, 2007) (Digest)
G.R. No. 177749 December 17, 2007
People of the Philippines vs. Manuel Aguilar
FACTS
The accused-appellant, Manuel Aguilar, was charged with the rape of AAA, the daughter of his common-law wife BBB, allegedly committed on June 24, 1997. The prosecution’s case primarily relied on the testimony of the victim’s mother, BBB. She testified that on the night of February 4, 1998, she discovered Aguilar naked and on top of the then 13-year-old AAA, who was also partially undressed. Upon confrontation, AAA revealed that Aguilar had sexual intercourse with her. This incident led to a medical examination on February 5, 1998, which confirmed the presence of spermatozoa. The defense, however, presented a different account. Aguilar claimed that on the said date, he was in a different location, working on a farm owned by a certain Mr. Lim, and presented an alibi supported by the testimonies of his employer and a co-worker.
ISSUE
The core issue for resolution was whether the prosecution successfully proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt, particularly in light of the conflicting testimonies and the defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony, especially when corroborated by an eyewitness, is paramount in rape cases. The detailed and consistent account of BBB, who caught the appellant in the act, was found to be credible and unshaken by cross-examination. The medical certificate, while stemming from the February 1998 incident, corroborated the fact of recent sexual intercourse. The Court gave little weight to the defense of alibi, which is inherently weak and easily fabricated. It was insufficient to overthrow the positive identification and the strong evidence presented by the prosecution. The alibi was not physically impossible, as the farm was not so distant as to preclude Aguilar’s presence at the crime scene. Furthermore, the defense failed to prove any ill motive on the part of the complainant and her mother to falsely accuse him. Consequently, the Court upheld the finding of guilt beyond reasonable doubt and sustained the penalty of reclusion perpetua and the awarded damages.