G.R. No. 248370 . October 14, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

The accused-appellant was charged with two counts of rape against his 11-year-old daughter, AAA. The prosecution’s evidence established that on June 14, 2009, the accused-appellant, while intoxicated, undressed AAA, mounted her, and inserted his penis into her vagina despite her pleas to stop. AAA immediately reported the incident to her mother. For the other charge covering June 1-13, 2009, AAA testified to another incident but could not recall the specific date.
The defense presented an alibi. The accused-appellant claimed he was at sea fishing on the night of June 14, 2009, and that AAA was under the care of her grandmother. His mother corroborated this, stating he fished nightly and returned in the morning. She admitted, however, that fishing was weather-dependent and he would not go during bad weather.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for Statutory Rape.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best left to the trial court. The testimony of the victim, AAA, was found to be credible, straightforward, and consistent on the material point of the rape committed on June 14, 2009. Her immediate reporting of the crime bolstered her credibility.
The Court rejected the defense of alibi for being inherently weak and unsubstantiated. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to be at the scene. The defense failed to establish this impossibility. The grandmother’s admission that the accused did not fish during inclement weather created a window of opportunity for him to have committed the crime.
The legal logic centers on the elements of Statutory Rape under Article 266-A(1)(d) of the Revised Penal Code. The crime is consummated by sexual intercourse with a woman under 12 years of age, regardless of her consent. The prosecution successfully proved that AAA was 11 years old at the time and that carnal knowledge occurred. The qualifying circumstance of relationship (father-daughter) was also duly established, warranting the penalty of reclusion perpetua without eligibility for parole. The award of damages was modified in line with prevailing jurisprudence.