GR 177770; (March, 2008) (Digest)
G.R. No. 177770; March 28, 2008
PEOPLE OF THE PHILIPPINES, Appellee, vs. JOSE HENRY ROBLES y NUDO, Appellant.
FACTS
Appellant Jose Henry Robles was charged with 54 counts of qualified rape against his 14-year-old niece, AAA. The prosecution alleged that the rapes occurred daily from August 1 to August 27, 2002, while AAA was staying in the appellant’s house due to flooding at her own home. AAA testified that the appellant, her uncle, first raped her on August 1, 2002, by threatening her with a gun and physical harm. She stated that the sexual assaults continued daily, with the appellant monitoring her movements to prevent her from reporting the crimes. The defense presented the appellant, who denied all charges, claiming AAA never stayed with him and that he was occupied with house renovations during the alleged period.
The Regional Trial Court convicted the appellant of only one count of simple rape for the incident on August 1, 2002, acquitting him of the other 53 charges due to insufficient evidence. The court found AAA’s testimony for the first incident credible but held that the repetitive nature of her account for the subsequent days lacked the requisite detail to establish each crime beyond reasonable doubt. The prosecution failed to present AAA’s birth certificate, so the qualifying circumstance of minority was not proven, reducing the crime from qualified rape to simple rape.
ISSUE
Whether the Court of Appeals erred in affirming the appellant’s conviction for one count of simple rape.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of AAA’s credibility regarding the rape on August 1, 2002. The detailed testimony of the victim on how the appellant initiated the assault, the threats employed, and her immediate physical pain and bleeding were consistent and credible. The medico-legal report confirming her non-virgin state corroborated her claim of sexual intercourse. The Court emphasized that in rape cases, the credibility of the victim is paramount, and AAA’s straightforward narration, coupled with her young age and relationship to the appellant, lent credence to her account.
The Court rejected the appellant’s defenses of denial and alibi. Denial is inherently weak and cannot prevail over the positive identification by the victim. His alibi, supported only by a stipulated testimony of a worker, was insufficient as he failed to prove it was physically impossible for him to be at the crime scene. The Court also agreed with the trial court’s acquittal on the other counts, as the prosecution did not meet the burden of proving each alleged rape with the same level of detail and certainty. The penalty of reclusion perpetua and the awarded damages were sustained.