G.R. No. 180925 ; August 20, 2008
The People of the Philippines, appellee, vs. Jaime del Castillo, appellant.

FACTS

The appellant, Jaime del Castillo, was charged with the rape of AAA, a 16-year-old minor, on June 29, 2002, in Calabanga, Camarines Sur. The prosecution evidence established that AAA was alone in her house when, at around 11:00 p.m., she was attacked. She identified the appellant, who poked a spoon at her neck, punched her, and forcibly had carnal knowledge of her. AAA immediately reported the incident to her aunt the following day, and they proceeded to the barangay captain, the police, and a hospital for a medico-legal examination. The examination revealed fresh hymenal lacerations and other injuries consistent with her testimony.
The appellant interposed the defense of alibi, claiming he was at a wedding celebration and subsequent drinking session from 10:00 a.m. until past midnight on the date in question. His testimony was corroborated by two witnesses. However, the prosecution presented a rebuttal witness who testified to seeing the appellant near the crime scene at approximately 11:00 p.m.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the appellant’s conviction. The Court upheld the findings of the trial court and the Court of Appeals, giving utmost credence to the testimony of the victim. The Court emphasized that in rape cases, the credibility of the complainant is paramount. AAA’s testimony was clear, consistent, and candid. Her immediate actions following the incident—reporting to her aunt, authorities, and undergoing a medical examination—lent credibility to her account and demonstrated spontaneity, which is inconsistent with a fabricated charge.
The Court found the defense of alibi weak and unavailing. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the scene. The appellant failed to establish this physical impossibility. The positive identification by the victim, who knew the appellant, prevailed over the alibi, which was further weakened by the rebuttal witness’s testimony placing him near the locus criminis. The medico-legal findings corroborated AAA’s account of forcible intercourse. Consequently, the Court sustained the penalty of reclusion perpetua and the awards of civil indemnity and moral damages. However, it deleted the award of exemplary damages, as no aggravating or qualifying circumstance attended the commission of the rape.