G.R. No. 228779 . October 08, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. WILLIAM VILLAROS Y CARANTO, ACCUSED-APPELLANT.

FACTS

Two Informations charged William Villaros with two counts of rape against his minor niece, AAA, on November 29 and December 27, 2009. The prosecution established that on both occasions, AAA was alone in their adjacent houses. The first incident occurred after Villaros lured her into his bedroom, where he forcibly undressed her, covered her mouth, and had carnal knowledge. The second rape happened when AAA was again alone, with Villaros similarly using force and intimidation, and threatening to harm her younger siblings if she reported him. AAA’s pregnancy was later discovered, leading to her disclosure. A medical examination revealed deep-healed hymenal lacerations, corroborating sexual abuse.
The defense relied on denial and alibi. Villaros claimed he was working at a construction site in a different barangay on November 29 and was in another municipality on December 27. He alleged that AAA fabricated the charges due to a grudge from a prior quarrel with his own nieces and nephews who lived with him. He denied any responsibility for her pregnancy and asserted he had no opportunity to commit the crimes.

ISSUE

The core issue is whether the prosecution proved Villaros’s guilt for two counts of rape beyond reasonable doubt, overcoming his defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s clear, consistent, and candid testimony, which withstood rigorous cross-examination, prevails over the weak defenses of denial and alibi. AAA’s detailed account of the force, intimidation, and threats, coupled with her young age and respectful address of “Tito,” rendered her testimony credible and natural. The medical findings of healed hymenal lacerations provided physical corroboration of sexual intercourse. The defense of alibi failed as Villaros did not prove it was physically impossible for him to be at the crime scene; the locations he cited were not so distant as to preclude his presence. Denial, being inherently weak, cannot prevail over positive identification. The Court also found the delay in reporting, due to the accused’s threats against AAA’s siblings, was sufficiently explained and did not impair her credibility. All elements of rape under Article 266-A of the Revised Penal Code were established: carnal knowledge through force and intimidation against a minor. The qualifying circumstances alleged in the Informations were correctly disregarded as they were not proven, but this did not affect the conviction for simple rape. The penalties and awards of damages imposed by the lower courts were sustained.