G.R. Nos. 76019-20 November 6, 1989
People of the Philippines, plaintiff-appellee, vs. Martin Bruca, defendant-appellant.

FACTS

Two separate complaints for rape were filed by sisters Nimpha and Monina Bruca against their father, Martin Bruca, before the Regional Trial Court of Iriga City. The charges stemmed from incidents on April 13, 1980, in their home in Barangay Caranday, Baao, Camarines Sur. Nimpha, then fourteen, alleged she was raped at around 11:00 AM after being carried to a room while sleeping. Monina, then thirteen, claimed she was raped at around 1:00 PM after being forced into the same room. The prosecution presented the testimonies of the complainants, their grandmother, and a rural health officer who conducted a medical examination. The defense consisted of denial and alibi, claiming the family was in a different barangay, La Medalla, until April 14 for a novena and baptism following their mother’s death.
The trial court convicted Martin Bruca in a consolidated decision, sentencing him to two penalties of reclusion perpetua. The court found the testimonies of the young complainants credible and rejected the defense’s alibi. The case was elevated to the Supreme Court on appeal.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly in light of the defense of alibi and the challenge to the credibility of the complainants.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of witnesses, especially in rape cases, is a matter best assessed by the trial court. It found no reason to deviate from the trial court’s findings, as the testimonies of Nimpha and Monina were straightforward, consistent, and detailed in describing the force, intimidation, and sexual acts committed by their father. Their immediate reporting to their grandmother and subsequent medical examination bolstered their credibility.
The Court categorically rejected the defense of alibi. For alibi to prosper, the accused must demonstrate it was physically impossible for him to be at the crime scene. The evidence showed the distance between La Medalla and Caranday was not prohibitive; the family could have traveled in the morning and been at their home by 9:00 AM, well before the rapes occurred at 11:00 AM and 1:00 PM. The Court also dismissed the appellant’s claim that the complaints were instigated by a familial dispute over child custody, noting it was inconceivable that a grandmother would subject her young, motherless granddaughters to the ordeal of a rape trial out of mere spite.
The presence of the aggravating circumstance of relationship (the accused being the father) was inherent in the charge and warranted the imposition of the supreme penalty. The Court upheld the sentences of reclusion perpetua for each count, stressing the reprehensible nature of the crimes committed against the accused’s own daughters.