G.R. No. 179277; June 18, 2008
THE PEOPLE OF THE PHILIPPINES, appellee, vs. REMON COJA y SIMEON, appellant.

FACTS

The appellant, Remon Coja y Simeon, was charged with the rape of AAA, a 16-year-old minor, on May 1, 2001, in Noveleta, Cavite. The prosecution’s narrative, as provided by AAA, stated that while she was returning to her sister at a vacant lot, she heard a whistle from the appellant. Two unidentified men then held her, and appellant covered her nose and mouth with a handkerchief, causing her to lose consciousness. She regained consciousness in a different vacant lot, finding her pants down and experiencing pain. She crawled to her godfather’s house, repeatedly uttering appellant’s name. A medico-legal examination confirmed recent genital injury, though the hymen was intact.
The defense interposed alibi, claiming appellant was in Kawit, Cavite, attending a meeting de avance at the time of the incident. This was corroborated by a witness and appellant’s mother. The Regional Trial Court found appellant guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua, awarding civil indemnity and moral damages. The Court of Appeals affirmed the decision in toto, prompting this automatic review.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the appellant for the crime of rape beyond reasonable doubt, overcoming his defense of alibi and the medico-legal finding of an intact hymen.

RULING

The Supreme Court affirmed the conviction. The Court held that the credible and categorical testimony of the victim, AAA, sufficiently established all the elements of rape. Her positive identification of the appellant, her immediate report to her godfather naming “Coja,” and her subsequent identification at the police station constituted a consistent and credible narrative. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of alibi was correctly rejected for being inherently weak and unsubstantiated. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the scene of the crime. Appellant failed to prove such impossibility, as Kawit and Noveleta are neighboring municipalities. Furthermore, the medico-legal finding of an intact hymen is not incompatible with rape, as penetration sufficient to constitute carnal knowledge is not equated with hymenal rupture. The recent genital injury noted by the physician corroborated AAA’s account of violation. Thus, the totality of evidence met the required quantum of proof beyond reasonable doubt.