G.R. No. 187077 ; February 23, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALEX CONDES Y GUANZON, Accused-Appellant.

FACTS

Accused-appellant Alex Condes y Guanzon was charged with the rape of his 14-year-old stepdaughter, AAA, on or about February 14, 1999, in Bay, Laguna. The information alleged he used force, violence, intimidation, and a bolo to have carnal knowledge against her will. The prosecution’s evidence, as summarized by the OSG, stated that on the evening of February 14, 1999, AAA was alone with the accused in their house. He entered the room where she was cleaning, pointed a bolo at her neck, threatened her, pulled her to the floor, removed her clothes, and succeeded in having sexual intercourse with her despite her resistance. He threatened to kill her siblings if she told anyone. AAA revealed the incident in December 1999 after another attempted rape. A medical examination on January 4, 2000, by Dr. Joselito Rodrigo revealed a deep-healed hymenal laceration and findings compatible with a 9 to 10-week pregnancy. The defense presented denial and alibi. Accused claimed he was in Quezon City and Albay around the time of the incident and presented witnesses, including a co-worker and a barangay captain, to support his whereabouts. The RTC convicted him of simple rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral, and exemplary damages. The CA affirmed the RTC decision. The accused appealed, arguing the trial court failed to consider AAA’s alleged motive to file the case (resentment over his discipline and fear of punishment for her pregnancy) and that his participation was not proven with certainty.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the findings of the lower courts, giving great weight to the assessment of AAA’s credibility, which was found to be natural, convincing, and consistent. The Court rejected the defense of alibi as weak and unsubstantiated, especially when contrasted with AAA’s positive identification. The alleged ill motive was deemed insufficient to overturn the credible testimony of the victim. The Court applied the guiding principles in rape cases: accusations are easy to make but hard to disprove; the complainant’s testimony must be scrutinized with extreme caution; and the prosecution’s evidence must stand on its own merits. The victim’s testimony, corroborated by medical findings, was found to be credible and sufficient to prove guilt beyond reasonable doubt. The Court affirmed the penalty of reclusion perpetua and the awarded damages.