G.R. No. 90390 . October 31, 1990.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODANTE FELIPE, defendant-appellant.

FACTS

The accused-appellant, Rodante Felipe, was convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua. The prosecution’s evidence established that on June 20, 1987, in Quezon, the 12-year-old complainant Rosalie Revilla was assaulted in her home. Her parents were away, leaving her and her younger sister under the care of their sister-in-law, Erlinda. Rosalie testified she was awakened by pain in her private parts to find the appellant on top of her, having carnal knowledge. She shouted, struggled, and kicked him, enabling her to break free. As she tried to flee, the appellant caught her, boxed and slapped her, and strangled her until she lost consciousness.
Erlinda, alerted by the shouts, went to the house with a lamp and saw the appellant fleeing. She found Rosalie unconscious on the floor, with her panty pulled down and her private parts bleeding. Rosalie, upon regaining consciousness, told Erlinda she was raped by “Dante.” A medical examination confirmed recent sexual intercourse, finding redness and congestion around the vaginal opening, an absent hymen, and the presence of whitish fluid. The defense was alibi, claiming the appellant was fishing at sea during the alleged incident.

ISSUE

Whether the trial court erred in convicting the appellant, as the prosecution’s evidence allegedly failed to meet the required moral certainty and overcome the constitutional presumption of innocence.

RULING

The Supreme Court affirmed the conviction. The Court found the complainant’s testimony credible, straightforward, and consistent. It held that the alleged improbabilities in her narration—such as waking up only upon feeling pain rather than at the initial contact—were more apparent than real and did not detract from her credibility. The Court noted that it is not unusual for a victim to be awakened by the pain of penetration itself. The medical findings and the corroborative testimony of the sister-in-law, Erlinda, who witnessed the appellant fleeing and the victim’s condition, strongly corroborated the fact of rape.
The defense of alibi was correctly rejected. Alibi is inherently weak and cannot prevail over the positive identification of the accused by the victim, who was a long-time neighbor and had no motive to falsely accuse him. The Court emphasized that in rape cases, the testimony of a victim, if credible, is sufficient to sustain a conviction. All elements of rape under Article 335 of the Revised Penal Code were proven: carnal knowledge through force and intimidation, committed against a minor. The appealed judgment was affirmed, with the modification of increasing the civil indemnity to Fifty Thousand Pesos (P50,000.00).