G.R. No. 178067; August 11, 2008
People of the Philippines, plaintiff-appellee, vs. Abdelkarim Ahmad Alkodha, accused-appellant.

FACTS

The accused-appellant, Abdelkarim Ahmad Alkodha, was convicted by the Regional Trial Court of Pasig City for two counts of rape against AAA, a saleslady he hired. The prosecution’s evidence established that on March 14, 2004, after a day of errands, Alkodha forcibly dragged AAA into his room, covered her mouth, boxed her, and raped her, threatening to kill her if she reported it. The following night, March 15, he again dragged her into his room, assaulted her, and raped her a second time. AAA escaped the next day and immediately reported the incidents, with a medical examination revealing physical findings compatible with recent sexual intercourse and loss of virginity.
The defense presented a denial and alibi. Alkodha claimed he was at a baptismal party and other locations during the evening of March 14, and that AAA left his store on March 16 after a scolding, later fabricating the rape complaint because he refused her request for a cash advance. He presented witnesses, including a police officer, to corroborate his whereabouts and reported AAA’s disappearance to the police blotter preemptively.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s clear, consistent, and candid testimony, which withstood rigorous cross-examination, prevails over the weak defenses of denial and alibi. AAA’s detailed account of the sequential events, including her immediate escape and reporting, lent credibility and demonstrated natural behavior. The medical findings corroborated her claim of recent sexual assault.
The defense of alibi was rejected as it was not physically impossible for Alkodha to have been at the crime scene at the time of the incidents. His own timeline left room for his presence. His claim of a fabricated charge due to a denied cash advance was deemed inherently improbable, as it fails to explain why a young woman would subject herself to the ordeal of a public rape trial for such a trivial motive. The act of reporting AAA’s disappearance to the police blotter before any formal complaint was filed was seen as a preemptive tactic to discredit her, not proof of innocence. Thus, the totality of evidence sustained a finding of guilt beyond reasonable doubt.