G.R. No. 187049; May 4, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LITO MACAPANAS y ECIJA, Accused-Appellant.

FACTS

On December 7, 1999, AAA was walking to a waiting shed in Salcedo, Eastern Samar when appellant Lito Macapanas, wearing a makeshift mask and armed with a sundang, grabbed her. He dragged her to an isolated hut, forced her to undress, and had carnal knowledge with her against her will. After the act, as they walked back and AAA saw people, she shouted for help. Appellant then stabbed her in the back before fleeing. AAA was hospitalized. Initially, she only reported the stabbing to the police. Days later, she confided to her mother and a doctor that she had also been raped, which was corroborated by a medical finding of a partially healed hymenal laceration.
The defense presented an alibi, claiming appellant was at home gathering coconuts on the day in question. He denied the accusations and suggested that AAA’s identification was unreliable because she only named him as her assailant days after the incident and after initially telling police she was merely stabbed.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that appellant is guilty of the crime of rape.

RULING

The Supreme Court affirmed the conviction. The Court found AAA’s testimony credible, straightforward, and consistent on the material points of the rape. The delay in disclosing the rape was satisfactorily explained by her fear, given the appellant’s threat to kill her if she told anyone, and the traumatic nature of the crime. The medical certificate, indicating a hymenal laceration, provided physical corroboration. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of alibi was rejected as inherently weak and could not prevail over AAA’s positive identification. The Court noted that 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 have been at the scene. Appellant failed to establish such physical impossibility. The minor inconsistencies in AAA’s statements, such as the initial failure to immediately report the rape, were deemed inconsequential and did not damage her core narrative. The force and intimidation were evident from appellant’s use of a weapon, his threats, and the subsequent stabbing. Thus, the elements of rape through force and intimidation were proven beyond reasonable doubt. The penalty of reclusion perpetua was affirmed.