G.R. No. 222497 . June 27, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. PEDRO RUPAL, ACCUSED-APPELLANT.

FACTS

The accused-appellant, Pedro Rupal, was charged with the rape of AAA, a minor, on December 15, 2005. The prosecution’s version established that Rupal, a relative by marriage, lured AAA to a waiting shed near her school under the pretext of giving her money from her mother. Later that afternoon, he returned, forcibly dragged her to a coconut plantation, and had carnal knowledge of her despite her resistance and tears. He threatened to kill her mother and siblings if she reported the incident, which caused AAA to remain silent. The rape was only revealed in early January 2006 after Rupal chased AAA, prompting her aunt to intervene. AAA then confessed to her mother about the December incident and multiple prior rapes since she was nine. A medical examination confirmed vaginal penetration.
The defense presented a denial and alibi. Rupal claimed he was at home gardening and fetching water during the alleged incident and suggested the charge was fabricated due to a family quarrel between his wife and AAA’s mother. He asserted he did not commit the crime and did not submit a counter-affidavit upon his arrest.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s detailed, candid, and consistent narration of the forcible sexual assault and the subsequent threat was found to be credible and sufficient to establish guilt. Her initial silence, explained by the accused’s death threats against her family, was reasonable and did not undermine her credibility. The medical findings, which indicated a healed lacerated wound consistent with forcible penetration, corroborated her account.
The Court rejected the defense of denial and alibi for being inherently weak and uncorroborated. Denial cannot prevail over the positive and credible testimony of the victim. Furthermore, for alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene, which Rupal failed to do as his claimed location was not far from the school. The alleged motive for fabrication—a family quarrel—was deemed insufficient to overturn the clear and convincing evidence presented by the prosecution. Thus, all elements of rape under Article 266-A of the Revised Penal Code were proven beyond reasonable doubt.