G.R. No. 179189 ; February 26, 2008
THE PEOPLE OF THE PHILIPPINES, appellee, vs. REYNALDO RESUMA y AGRAVANTE alias “GEROM,” appellant.

FACTS

Appellant Reynaldo Resuma was charged with two counts of rape committed against AAA, the daughter of his live-in partner. The first incident allegedly occurred on December 8, 1994, when AAA was home washing dishes and babysitting. Appellant followed her into a bedroom, forced her to lie on her stomach, and had carnal knowledge of her. The second incident occurred in August 1995 under similar circumstances. AAA reported the incidents to her older sister, DDD. Their father, BBB, eventually learned of the rapes and brought AAA to the police and for a medico-legal examination, which confirmed recent lacerations consistent with sexual intercourse.
The defense interposed denial and alibi. Appellant claimed he was elsewhere during the alleged incidents, attending a fiesta and working as an umbrella repairman. He alleged the charges were fabricated by BBB to gain custody of the children. Appellant’s live-in partner, CCC (AAA’s mother), testified for the defense, denying any knowledge of the rapes and claiming she was always home with the children.

ISSUE

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

RULING

The Supreme Court affirmed appellant’s conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA gave a clear, consistent, and candid account of the two incidents, which was corroborated by her sister DDD and the medico-legal findings. The medical report, indicating healed and fresh lacerations, objectively supported her claim of recent sexual violation. The Court found no ill motive for AAA, a minor, to falsely accuse her stepfather.
The defenses of denial and alibi were rightly rejected. Denial is inherently weak and cannot prevail over the positive identification and credible testimony of the victim. 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. The affirmative testimony of the victim, who identified him as the perpetrator, prevails. The Court also noted that the victim’s failure to immediately report the rapes to authorities, due to fear and the perpetrator’s moral ascendancy as a stepfather, does not undermine her credibility. The conviction for two counts of rape and the penalty of reclusion perpetua for each count were upheld.