GR 225642; (January, 2018) (Digest)
G.R. No. 225642 -43, January 17, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JUVY D. AMARELA AND JUNARD G. RACHO, Accused-Appellants
FACTS
The accused-appellants, Juvy D. Amarela and Junard G. Racho, were charged with two counts of rape. The victim, AAA, testified that on February 10, 2009, while at a fiesta, Amarela forcibly dragged her under a stage, punched her, and raped her. After escaping, she was assisted by Godo Dumandan to the Racho residence. Racho’s mother then instructed Racho to escort AAA home. Instead, Racho brought her to a shanty, boxed her when she resisted, and also raped her. AAA reported the incidents the following day.
The defense presented alibis and denials. Amarela claimed he was drinking and later unconscious at his brother’s house during the alleged first rape. Racho admitted escorting AAA but denied raping her, asserting he could not have done so due to an impaired left arm from a prior hacking incident, for which he presented a medical certificate.
ISSUE
Whether the guilt of accused-appellants Amarela and Racho for the crimes of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the convictions. The Court upheld the factual findings of the lower courts, giving great weight to AAA’s credible, consistent, and categorical testimony. The defense of alibi by Amarela was weak and could not prevail over the positive identification by the victim. For Racho, the Court found his claim of physical incapacity unpersuasive. The medical certificate only proved a past injury and confinement; it did not establish that his arm was still in a cast or completely immobile on the date of the crime. Racho himself admitted he had removed the cast months prior. His impairment, therefore, did not preclude the commission of the act.
The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The alleged inconsistencies in AAA’s testimony were minor and did not affect her core narrative. The medical findings, which noted healed lacerations, were consistent with her account, considering the examination occurred days after the incidents. The appeals were denied, and the penalties imposed by the Court of Appeals were affirmed.