G.R. No. 207946 . September 27, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ALFREDO REYES ALIAS “BOY REYES,” ACCUSED-APPELLANT.

FACTS

The accused, Alfredo Reyes, was charged with Rape with Homicide for the death of Lerma Leonora on February 13, 1998. The prosecution’s case rested primarily on the testimony of the victim’s eight-year-old niece, Charmaine Leonora. She testified that she was sleeping beside her aunt when she was awakened by Reyes entering their room. She witnessed Reyes strike Lerma’s forehead with a stone, rendering her unconscious. Reyes then dragged Lerma to the kitchen where Charmaine, hiding nearby, saw him remove Lerma’s shorts, take off his own pants and jacket, and mount her, making push and pull movements. Reyes threatened to kill Charmaine and her parents if she reported the incident. Medical findings confirmed fresh hymenal lacerations and spermatozoa in the victim’s vagina, with the cause of death being massive intracranial hemorrhage from a traumatic head injury.
Reyes interposed the defense of denial and alibi. He claimed he was asleep in his house with his son on the night of the incident and only learned of the crime the next morning. He alleged his house was robbed that night, and his pants and his son’s jacket were stolen, implying these were the same garments found at the crime scene. He reported the theft to the police but was subsequently detained for the crime. He denied knowing the victim and claimed he did not see Charmaine on the dates in question.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of Rape with Homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of child witness Charmaine Leonora to be credible, convincing, and consistent with the physical evidence. The Court emphasized that testimonies of child victims are given full weight and credit, as youth and immaturity generally make them incapable of fabrication. Her detailed account of the violent attack and the sexual assault was corroborated by the medico-legal findings of fresh hymenal lacerations, the presence of spermatozoa, and the fatal head wound. The defense of denial and alibi was deemed inherently weak and could not prevail over the positive identification by the eyewitness. Alibi must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the crime scene, which Reyes failed to establish. His claim that his clothing was stolen was a bare assertion unsupported by evidence and was contradicted by his positive identification. The Court upheld the factual findings of the lower courts, noting that the assessment of witness credibility is best undertaken by the trial court. The crime was qualified as Rape with Homicide under Article 266-B of the Revised Penal Code, as the killing of the victim was committed by reason or on the occasion of the rape. The penalty was reduced to reclusion perpetua without eligibility for parole, in accordance with prevailing jurisprudence, and civil indemnities were awarded to the victim’s heirs.