GR 182454; (July, 2009) (Digest)
G.R. No. 182454 ; July 23, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FELIX WASIT, Accused-Appellant.
FACTS
The accused-appellant, Felix Wasit, was charged with the rape of AAA, a 13-year-old boarder in his family’s house. The prosecution evidence established that in the early morning of November 5, 1997, AAA was awakened by pain as someone was on top of her, covering her mouth. She recognized Wasit’s voice as he told her not to shout after penile penetration. AAA managed to free herself, cried out, and later reported the incident to Wasit’s sister and other boardmates. One boardmate testified to hearing AAA shout “Satanas ka Felix,” while another heard Wasit utter, “Stop, that’s enough it’s my fault.” A medical examination days later revealed a hymenal laceration.
The defense presented an alibi, with Wasit claiming he was asleep at the time and had a normal breakfast with AAA the next morning. He and his siblings testified that AAA had planned to transfer boarding houses and that there was no unusual occurrence. The Regional Trial Court convicted Wasit of rape and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals.
ISSUE
The core issue is whether the prosecution proved Wasit’s guilt for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court held that AAA’s categorical, consistent, and credible testimony, corroborated by the testimonies of immediate witnesses and medical findings, sufficiently established the fact of rape. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. AAA’s positive identification of Wasit as her assailant, her prompt outcry, and the corroborating statements of boardmates who heard the commotion and Wasit’s incriminating plea for forgiveness collectively constituted proof beyond reasonable doubt.
The Court rejected the defense of alibi as weak and unsubstantiated, noting it cannot prevail over the positive identification by the victim. The defense failed to demonstrate it was physically impossible for Wasit to be at the crime scene. The Court also found no ill motive for AAA to falsely accuse Wasit. The award of damages was modified in line with prevailing jurisprudence, increasing the exemplary damages to Php 30,000. The conviction and the penalty of reclusion perpetua were upheld.