G.R. No. L-50386 August 8, 1988
People of the Philippines, plaintiff-appellee, vs. Jose San Buenaventura, defendant-appellant.

FACTS

The accused, Jose San Buenaventura, was charged with the rape of his half-sister, Julita San Buenaventura, who was under twelve years old at the time of the incident on June 14, 1975. The prosecution’s evidence established that on that date, while Julita’s mother was away, the accused ordered Julita upstairs, forced her to lie down, and had carnal knowledge of her. The crime was discovered the next day when Julita’s father noticed blood on her legs. A medical examination confirmed recent sexual intercourse and vaginal injuries.
The defense presented an alibi, claiming the accused was working in a field with his father approximately 200 meters away during the alleged time of the rape. The defense also highlighted an inconsistency: during an initial hospital investigation on June 15, Julita pointed to a certain Mario Bamba as the perpetrator, but the following day, she identified the accused. The trial court convicted the accused of statutory rape under Article 335(3) of the Revised Penal Code, imposing reclusion perpetua.

ISSUE

The core issue is whether the trial court erred in convicting the accused based primarily on the victim’s testimony, despite the presented alibi and the initial inconsistency in her identification.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the nature of statutory rape and the evaluation of evidence. First, under Article 335(3), the gravamen of statutory rape is carnal knowledge of a woman below twelve years old; force, intimidation, or consent become immaterial. Thus, the prosecution only needed to prove Julita’s age and the fact of sexual intercourse, which were sufficiently established by her testimony and the medical certificate.
Second, the Court found the victim’s testimony credible and convincing. The initial misidentification of Mario Bamba did not destroy her credibility. The Court recognized that a young, traumatized victim, threatened by her own half-brother, might initially be hesitant or confused. The prompt correction of her statement the very next day, under proper investigation, indicated reliability rather than fabrication. The moral ascendancy of the accused as an elder half-brother living in the same house explained the delay in reporting and the initial fear.
Third, the defense of alibi was rightly rejected. For alibi to prosper, the accused must demonstrate it was physically impossible for him to be at the crime scene. The accused admitted the field was only about 200 meters from the house, a distance that did not preclude his presence at the locus criminis. This short distance rendered his alibi untenable, especially compared to other cases where alibi was dismissed for much greater distances. The alibi lacked corroboration and was inherently weak against the positive identification by the victim. The decision was affirmed with an increase in civil indemnity.