GR 185712; (August, 2009) (Digest)
G.R. No. 185712 ; August 4, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LILIO U. ACHAS, Accused-Appellant.
FACTS
The accused-appellant, Lilio U. Achas, was convicted by the Regional Trial Court of two counts of rape committed against AAA, the eight-year-old daughter of his common-law spouse. The first incident occurred in June 1998, where Achas, armed with a knife, forced himself on the victim inside their home. The second rape happened in July 1999, during which he again used a knife to threaten AAA and covered her mouth with a towel. The crimes were discovered after AAA was found to be afflicted with gonorrhea. Achas denied the accusations, interposing the defense of alibi, claiming he was in Bukidnon during the alleged incidents. His son, CCC, testified that two other boys were the perpetrators, allegedly coached by AAA’s aunt, EEE, who supposedly bore a grudge against Achas.
ISSUE
Whether the Court a quo gravely erred in convicting the accused despite the failure of the prosecution to prove his guilt beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court held that the categorical, consistent, and straightforward testimony of the victim, AAA, who was a minor at the time of the assaults, was sufficient to establish the elements of rape through force and intimidation. The Court emphasized that the testimony of a child-victim, given in a candid and natural manner, deserves full credence. The defense of alibi and denial proffered by Achas was inherently weak and could not prevail over the positive identification by the victim. The Court noted that for alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the scene of the crime, which Achas failed to do. Furthermore, the alleged motive of the aunt to fabricate charges was insufficient to overturn the conviction, as no evidence showed that AAA herself had any ill motive to falsely accuse her stepfather. The findings of the trial court on the credibility of witnesses are accorded great weight and respect. The penalty was modified from death to reclusion perpetua without eligibility for parole for each count, in accordance with Republic Act No. 9346 , and the awards of damages were sustained.