G.R. No. 243987 . September 23, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BBB, ACCUSED-APPELLANT.

FACTS

Accused-appellant BBB was charged with two counts of rape against his minor stepdaughters, AAA and CCC, and with violation of Republic Act No. 9262 (Violence Against Women and Their Children) for causing mental anguish to their mother, DDD, his common-law wife. The prosecution alleged that on December 10, 1999, BBB raped 13-year-old AAA in their home, threatening her with a gun. On March 30, 2004, he also raped 13-year-old CCC under similar circumstances of force and intimidation. The victims disclosed the incidents to their mother in April 2004, leading to a report with the National Bureau of Investigation. Medical examinations confirmed old hymenal lacerations consistent with loss of virginity.
BBB denied the accusations, interposing alibi and denial. For the first incident, he claimed he was on military duty in Jolo, Sulu. For the second, he asserted he was at home in a business meeting with a neighbor until the early morning, and that CCC was not present. The defense presented the neighbor to corroborate his alibi for the second incident, suggesting the complaints were fabricated because DDD wanted to be with another man.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for two counts of rape and violation of R.A. No. 9262 beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the convictions. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. The testimonies of AAA and CCC were found to be clear, straightforward, and categorical, detailing the acts of sexual assault and the threats made by their stepfather. The medical findings, while not conclusive of rape, lent credence to their claims. The Court consistently holds that the testimony of a minor victim, when credible, is sufficient to sustain a conviction.
The defenses of alibi and denial are inherently weak and cannot prevail over the positive identification and credible narration of the victims. 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 be at the scene. BBB failed to prove this impossibility for either incident. His denial, unsupported by clear evidence, carries no weight against the affirmative testimonies. The alleged motive for fabrication was deemed insufficient to overturn the consistent and credible accounts of the victims. Consequently, the Court upheld the penalties imposed by the lower courts, including reclusion perpetua for each count of rape.