### **Facts:**
On February 20, 2007, Antonio Balcueva y Bondocoy (Balcueva) was charged with the qualified rape of his biological daughter, AAA, in Quezon City, Philippines. The prosecution alleged that on February 15, 2007, Balcueva raped AAA around 2 p.m. after asking AAA’s siblings to leave the house. He then threatened AAA, removed her clothing, and proceeded to have carnal knowledge of her against her will. This series of events was partly witnessed by a neighbor who, along with AAA’s sister, reported the incident to the local authorities, leading to Balcueva’s apprehension.
Balcueva countered with a defense of denial and alibi, stating that at the time of the alleged rape, he was repairing appliances and had a confrontation with AAA over her request to go out, which he denied.
The Regional Trial Court (RTC) of Quezon City found Balcueva guilty beyond reasonable doubt, sentencing him to reclusion perpetua without parole and ordering him to pay damages. Not convinced, Balcueva appealed to the Court of Appeals (CA), which affirmed the RTC’s decision. Subsequently, Balcueva filed an ordinary appeal to the Supreme Court (SC).
### **Issues:**
1. Whether the testimony of the victim was credible and sufficient to establish guilt beyond reasonable doubt.
2. Whether Balcueva’s defense of denial and alibi could overthrow the victim’s positive identification and testimony.
3. The appropriate damages and penalties for qualified rape under Philippine law.
### **Court’s Decision:**
The Supreme Court affirmed the conviction by the lower courts, fully upholding the credence and sufficiency of AAA’s testimony over Balcueva’s defense. The Court emphasized the improbability of AAA fabricating such accusations against her father and undergoing the ordeal of a trial if the rape did not occur. The conviction was grounded on the direct, categorical, and unwavering identification of Balcueva as the perpetrator by AAA.
### **Doctrine:**
The case reaffirms the principle that in rape cases, the victim’s credible testimony alone can suffice to establish the defendant’s guilt beyond reasonable doubt. The SC also reinforced the doctrine that a denial or alibi cannot prevail over the positive identification and credible testimony of the complainant in rape cases.
### **Class Notes:**
– **Qualified Rape Elements:** (a) the victim is a female over 12 years but under 18 years of age; (b) the offender is a parent or relative within the third civil degree; (c) carnal knowledge is achieved through force, threat, or intimidation.
– **Credibility of Testimony:** A rape victim’s testimony, when credible and consistent, can be the sole basis for conviction.
– **Denial and Alibi:** These defenses are generally weak against unyielding positive identification and testimonies.
### **Historical Background:**
This case reflects the rigorous legal standards and protections provided under Philippine law for the victims of sexual violence, particularly minors and those assaulted by individuals in positions of power or trust over them. It underscores the country’s commitment to upholding justice for victims of rape and sexual abuse, emphasizing the importance of credible testimony and the challenges in proving such cases.
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