G.R. No. 234323 . January 7, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JORDAN BATALLA y AQUINO, Accused-Appellant.

FACTS

The accused-appellant, Jordan Batalla, was charged with rape under Article 266-A of the Revised Penal Code in relation to R.A. No. 7610 . The prosecution alleged that on August 5, 2011, in Camiling, Tarlac, Batalla, by means of threat and intimidation, had carnal knowledge of AAA, a 14-year-old minor, against her will. AAA testified that she was asleep in her aunt’s house when Batalla, a friend of her cousin, entered, threatened to kill her, and proceeded to rape her twice. She reported the incident days later after her mother discovered an entry in her diary. A medical examination revealed an old hymenal laceration.
Batalla interposed the defense of alibi, claiming he was at his mother’s birthday party in his house, located two blocks away, from the evening until past midnight of the alleged incident. His mother and a guest corroborated his presence at the party. The Regional Trial Court found him guilty beyond reasonable doubt, a decision affirmed by the Court of Appeals. Batalla appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming Batalla’s conviction for rape based on the credibility of the victim’s testimony and the weakness of his defense of alibi.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modification on damages. The Court upheld the findings of the lower courts, emphasizing that the victim’s categorical, consistent, and straightforward testimony deserves full faith and credit, especially as she was a minor. The Court reiterated the doctrine that when a woman, particularly a child, testifies she has been raped, she says all that is necessary to prove the commission of rape, provided her testimony is credible.
The Court found Batalla’s defense of alibi inherently weak. For alibi to prosper, the accused must prove not only his presence elsewhere but also the physical impossibility of his being at the scene of the crime. Here, Batalla’s house was merely two blocks away from the crime scene, a distance easily negotiable within minutes, thus negating any physical impossibility. His alibi, supported by relatives and friends, could not prevail over the positive identification by the victim. Denial, like alibi, is an intrinsically weak defense that cannot overcome positive testimony.
The penalty of reclusion perpetua was correctly imposed. However, following prevailing jurisprudence, the Court modified the awards of damages, increasing exemplary damages to Seventy-Five Thousand Pesos (Php75,000.00) to be consistent with the amounts for civil indemnity and moral damages. All damages shall earn legal interest at 6% per annum from finality of judgment until fully paid.