People vs. Medina, G.R. No.

179948, 8 December 2010

Del Castillo, J.

FACTS: Found guilty for qualified rape, accused-appellant assailed his conviction for not having
been found guilty beyond reasonable doubt, impugning the credibility of AAA, and avering that
the latter’s testimony about her hands and feet being tied while asleep to facilitate the
consummation of rape to be unbelievable considering that their house was so small and several
people were sleeping beside her on the same mat.

ISSUE: Was accused-appellant guilty beyond reasonable doubt?

RULING: Denial is inherently a weak defense. To be believed, it must be supported by strong

evidence of positive assertions; otherwise, such denial is purely self-serving and has practically no
evidentiary value vis a vis the positive declaration of a credible witness.

The Court held that appellant’s defense of denial was properly rejected. All that was on record was
his bare and uncorroborated protestations that he did not rape his minor daughter. He did not
proffer evidence to substantiate his averments. Between the positive assertions of the victim and
the negative averments of appellant, the former indisputably deserved more credence and were
entitled to greater evidentiary weight. Thus, the positive identification made by the victim of
appellant as the person who inserted his penis into her vagina plainly prevailed over his denial.