G.R. No. 202976 - People vs. Gahi

Appellant Mervin Gahi was charged with two counts of rape committed against AAA, a 16-year-old girl, as charged in Criminal Cases Nos. 4202 and 4203.
The offenses were alleged to have occurred on March 11 and March 12, 2002 in the Municipality of Capoocan, Province of Leyte.
The trial court initially convicted Gahi and imposed the death penalty, which was later modified by the Court of Appeals to reclusion perpetua with corresponding monetary damages.

AAA, residing in Leyte, was alone in her grandmother’s (BBB’s) house, engaged in household activities (mopping the floor).
Appellant, a frequent visitor due to his work making charcoal in the premises, arrived armed with a knife and ordered her to lie down.
He forcibly grabbed her, lifted her skirt, removed her underwear, and while brandishing a knife (with the blade approximately 6 inches long), he proceeded to insert his penis into her vagina until ejaculation occurred.
AAA experienced fear and physical weakness from the assault and was warned by Gahi to keep the incident secret under the threat of further harm.

While AAA was on her way to a field with a carabao, she encountered Gahi, who chased her to her grandmother’s house.
Inside the premises, Gahi again used a knife to intimidate her, forced her to lie down in the living room, removed her underwear and inserted his penis into her vagina with a “pumping” motion until blood was produced.
As with the first incident, AAA was induced by fear into submission without resistance and maintained silence about the crimes for fear of retribution.

AAA testified in open court, providing a detailed narrative of both rape incidents, including the use of force and intimidation.
A medical witness (Dr. Bibiana O. Cardente) and a social welfare officer (Ofelia Pagay) testified regarding AAA’s physical condition, pregnancy, and subsequent interventions by the DSWD.
Other testimonies were presented to corroborate elements of time, location, and circumstances (e.g., Filomeno Suson regarding the work schedule at the copra kiln dryer).

BBB, the 74-year-old grandmother, testified that she did not witness any unusual events and denied the occurrence of rape on both dates.
Filomeno Suson, a defense witness, presented an account of Gahi’s presence at the copra kiln dryer during the times of the alleged crimes, aiming to establish an alibi.
Jackie Gucela, a farm laborer who claimed a past intimate relationship with AAA, testified that he had previously been involved with the complainant and also admitted to fathering her child.
Gahi himself denied the allegations, contending that he was at the copra kiln dryer processing copra with his family, thereby making it physically impossible to be at the scene of the alleged rapes.

The Regional Trial Court of Carigara, Leyte, rendered its decision on April 22, 2005, convicting Gahi for two counts of rape and imposing the death penalty along with civil indemnity and exemplary damages.
The Court of Appeals, in its decision dated August 31, 2011, affirmed the conviction but modified the penalties by setting the sentence at reclusion perpetua for each count of rape and adjusting the awards for civil indemnity and exemplary damages.
Appellant’s appeal to the Supreme Court focused on the argument that the prosecution failed to prove his guilt beyond reasonable doubt, questioning the credibility and consistency of AAA’s testimony and contending that his alibi and alternative explanations (including the sweetheart theory via Jackie Gucela’s testimony) should have resulted in acquittal.

Whether the testimony of AAA, given its singular nature and minor discrepancies, was sufficient to sustain a conviction for two counts of rape.
Whether the inconsistencies in the victim’s account significantly undermined her testimony or if they could be seen as natural and minor in light of the trauma and complexity of the events.

Whether the defense’s presentation of an alternative intimate relationship (the sweetheart theory) involving Jackie Gucela and his acknowledgment of previous relations with AAA should negate or diminish the credibility of AAA’s account.
Whether the defense witnesses, particularly Filomeno Suson’s attempt to establish an alibi for Gahi, should have been accorded greater probative value given the physical proximity of the alleged crime scene to Gahi’s claimed work location.

Whether the distance and timing of Gahi’s presence at the copra kiln dryer sufficiently established that it was physically impossible for him to have committed the alleged rapes.
Whether the positive and categorical identification of Gahi by AAA nullified the alibi and denied the defense an opportunity for acquittal.