GR 230334; (August, 2019) (Digest)
G.R. No. 230334 . August 19, 2019.
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.
FACTS
The accused-appellant, XXX, was convicted by the trial court for three counts of qualified rape committed against his 16-year-old sister-in-law, AAA. The incidents allegedly occurred on April 16, 18, and 23, 2000, in Batangas. The prosecution’s version, as testified by AAA, was that on each occasion, the accused, armed with a knife, threatened and forcibly had carnal knowledge of her while she was alone in their house. She reported the rapes to her mother after the third incident, leading to a medico-legal examination which confirmed a hymenal laceration. The defense, however, presented an alibi, claiming the accused was working in a different barangay during the alleged dates and that AAA was working as a housemaid in Cavite. The defense evidence was corroborated by the accused’s wife (AAA’s sister) and a cousin.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s conviction of the accused-appellant for three counts of qualified rape.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment giving full credence to AAA’s categorical, straightforward, and consistent testimony, which was corroborated by the medico-legal findings. The Court reiterated the well-entrenched doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only that he was elsewhere when the crime occurred but that it was physically impossible for him to have been at the scene. The defense failed to prove this impossibility. The corroboration of the alibi by relatives was deemed insufficient, as such witnesses are often considered partial. The claim that AAA was in Cavite was unsubstantiated and contradicted by her clear and positive identification of the accused. The qualifying circumstance of relationship (brother-in-law) and the victim’s minority were duly proven, warranting the imposition of reclusion perpetua without eligibility for parole for each count. The awards of civil indemnity, moral damages, and exemplary damages were also affirmed in accordance with prevailing jurisprudence.