G.R. No. 264352 , December 04, 2023
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX264352, ACCUSED-APPELLANT.

FACTS

The accused-appellant, the brother-in-law of the 69-year-old complainant AAA, was charged with rape. The prosecution established that on December 10, 2016, at around 10:30 p.m., AAA was sleeping in her house when the accused-appellant entered, held her hands, and pushed her against a wall. AAA attempted to defend herself with a bolo but was overpowered. The accused-appellant then forced her onto a bed, pulled her clothing up, and had carnal knowledge of her against her will. Afterward, he threatened to return. AAA’s daughter, CCC, testified that she found her mother crying and in pain, and AAA immediately reported the rape. A medical examination conducted two days later confirmed the presence of spermatozoa in AAA’s vagina, compatible with recent sexual intercourse.
The defense presented an alibi, with the accused-appellant testifying that he was at a cockpit from 10:30 p.m. until 4:00 a.m. on the night in question and could not have committed the crime. The Regional Trial Court convicted the accused-appellant of rape under Article 266-A(1) of the Revised Penal Code, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals affirmed the conviction but modified the damages awarded. The accused-appellant appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modification to the damages. The Court held that all elements of rape under Article 266-A(1) were proven beyond reasonable doubt: (1) the accused had carnal knowledge of the victim, and (2) it was accomplished through force or intimidation. The testimony of AAA was clear, credible, and consistent. She provided a detailed account of the assault, including her resistance with a bolo, which was consistent with her age and the sudden attack. Her immediate reporting and the corroborative medical finding of spermatozoa fortified her credibility.
The Court rejected the defenses of denial and alibi. Denial is inherently weak and cannot prevail over the positive identification and categorical testimony of the victim. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene. The accused-appellant failed to prove this impossibility. The Court also found no merit in the argument that the absence of vaginal lacerations negated rape, as such physical findings are not necessary for conviction, especially with an elderly victim. The penalty of reclusion perpetua was affirmed. However, considering the victim was a 69-year-old senior citizen, the Supreme Court increased the awards for civil indemnity, moral damages, and exemplary damages to PHP 100,000.00 each, with 6% interest per annum from finality until fully paid.