G.R. No. 185723 ; August 4, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. EDWIN MEJIA, Accused-Appellant.

FACTS

On March 2, 2003, AAA, then a minor, was fetched by her mother BBB from her grandmother’s house to babysit her infant brother at BBB’s residence in San Carlos City, Pangasinan. BBB left for work, leaving AAA with BBB’s live-in partner, accused-appellant Edwin Mejia. That morning, while AAA was babysitting, Mejia, armed with a bolo, forcibly held her, laid her on the floor, and through force and intimidation, succeeded in having carnal knowledge with her. He threatened to kill her and her mother if she reported the incident. That same afternoon, Mejia again entered the bedroom, pulled her hair, and attempted to mount her but failed to insert his penis. Out of fear from the threats, AAA did not immediately report the rape, only disclosing it later when her pregnancy became evident.
The defense presented an alibi. Mejia claimed it was impossible for him to have committed the crimes as he was in Manaoag, Pangasinan, harvesting mangoes from March 1 to 3, 2003. He asserted his relationship with AAA was cold and aloof. The Regional Trial Court convicted Mejia of Rape for the morning incident and Acts of Lasciviousness for the afternoon attempt. The Court of Appeals affirmed the conviction. Mejia appealed to the Supreme Court.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of Rape and Acts of Lasciviousness beyond reasonable doubt, overcoming his defense of alibi and denial.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s clear, candid, and consistent narration of the harrowing events, including the specific details of force, intimidation, and penetration, was found credible and sufficient to establish the elements of rape. The Court noted that her initial silence and delay in reporting were satisfactorily explained by the accused’s threats against her and her mother’s life, which instilled genuine fear.
The defense of alibi was rightly rejected. 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. Mejia failed to establish this physical impossibility. The distance between San Carlos City and Manaoag, Pangasinan, is not such that travel was impossible within the timeframe. His denial, uncorroborated by strong evidence, cannot prevail over the positive identification and credible testimony of the victim. The Court modified the damages, awarding moral damages in line with prevailing jurisprudence. The appealed decision was affirmed with modification.