GR 199226; (January, 2014) (Digest)
G.R. No. 199226; January 15, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROEL VERGARA y CLAVERO, Accused-Appellant.
FACTS
The accused-appellant, Roel Vergara, was charged with the rape of AAA, a nine-year-old minor. The prosecution established that on September 12, 2004, AAA was alone in their house in Cavite City with Vergara, the common-law spouse of her mother. Vergara ordered AAA into a bedroom, forced her to undress, and had carnal knowledge of her despite her pleas and physical resistance. The incident was later reported, and a medico-legal examination confirmed AAA’s pregnancy, to which she eventually gave birth. Vergara, in his defense, interposed alibi, claiming he was at work in a nearby restaurant during the alleged time of the incident.
The Regional Trial Court convicted Vergara of simple statutory rape but did not appreciate the qualifying circumstance of relationship as he was not AAA’s legal stepfather but merely her mother’s live-in partner. The Court of Appeals affirmed the conviction. Vergara appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi should prevail over AAA’s testimony.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for the crime of statutory rape.
RULING
The Supreme Court affirmed the conviction. The Court held that the prosecution successfully proved all elements of statutory rape under Article 266-A(1)(d) of the Revised Penal Code: (1) AAA was under twelve years of age at the time of the incident, as evidenced by her birth certificate; and (2) sexual intercourse occurred, as detailed in AAA’s credible and categorical testimony, which was consistent and supported by the physical evidence of her pregnancy and the medico-legal findings. The Court emphasized that the testimony of a minor victim, especially one as young as AAA, is accorded full weight and credibility, particularly when the details are straightforward and unshaken by cross-examination.
The Court rejected Vergara’s defense of alibi as inherently weak and unsubstantiated. For alibi to prosper, the accused must demonstrate it was physically impossible for him to be at the crime scene. Vergara’s workplace was less than a kilometer away, a mere 30-minute walk, making it not only possible but plausible for him to have committed the crime. His denial could not overcome the positive identification and the strong evidence presented by the prosecution. The awards of civil indemnity and moral damages were sustained, while exemplary damages were increased to ₱30,000.00 in accordance with prevailing jurisprudence.