G.R. No. 236562 , September 22, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

The accused-appellant was charged with the statutory rape of his niece, AAA, who was seven years old at the alleged time of the crime in April 2000. The prosecution’s narrative, as affirmed by the trial court, detailed that the accused, taking advantage of being alone with the victim in their Quezon City home, forcibly raped her and threatened her with an ice pick to ensure her silence. The victim eventually disclosed the abuse to a neighbor in 2004 and later to her mother in 2008. Medical examinations in 2009 revealed a deep healed hymenal laceration, which the medico-legal officers opined was consistent with blunt force trauma such as from an erect penis.
During trial, the victim recanted her initial testimony and testified for the defense. The defense presented an alibi, arguing the physical improbability of the crime given the small, crowded living conditions where multiple family members were present. The accused-appellant also suggested the complaint was fabricated due to a familial dispute over financial remittances from the victim’s mother.

ISSUE

Whether the Court of Appeals erred in affirming the accused-appellant’s conviction for statutory rape despite the victim’s recantation and the defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that a recantation is inherently unreliable and viewed with extreme caution, as it can easily be obtained through coercion or monetary consideration. The victim’s initial testimony, given during her direct examination, was clear, convincing, and consistent with the medical findings. The medico-legal evidence provided strong corroboration for the commission of rape. The Court held that the positive identification and credible testimony of a rape victim, especially a minor, prevail over a denial and alibi.
Regarding the defense of alibi, the Court ruled it must be supported by clear and convincing evidence of the physical impossibility of the accused being at the crime scene. The accused-appellant failed to meet this burden, as he did not conclusively prove he could not have been with the victim during the alleged incidents. The claim of a crowded household did not negate the possibility of the crime, as rape can be committed even in places where people are present. The suggested motive for fabrication was deemed insufficient to overturn the consistent findings of the lower courts. Thus, the elements of statutory rape under Article 266-A of the Revised Penal Code were proven beyond reasonable doubt.