G.R. No. L-71173 August 9, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO DESUYO Y DIGOL, defendant-appellant.

FACTS

On January 2, 1980, in Pasay City, eight-year-old Aileen Olisco was lured by a man who pretended to get money from his house to pay for food. Instead, he dragged her to a garbage dump, threatened her with a knife, and raped her. The victim reported the crime immediately and was medically examined, confirming genital lacerations requiring suturing. Two weeks later, Aileen identified Reynaldo Desuyo from a set of photographs as her assailant. Upon his arrest on April 23, 1982, she positively identified him in a police line-up and again during trial, providing a clear and consistent account of her traumatic ordeal.
The defense presented an alibi, claiming Desuyo was working at a repair shop in Manila, approximately twelve kilometers away, at the time of the incident. Several witnesses, including the shop owner and neighbors, supported this claim. Some female witnesses also testified that they saw a different man fleeing the scene. However, the defense evidence was undermined by inconsistencies; one witness mistakenly dated her interaction with Desuyo to 1978, and others admitted they did not witness the rape itself and had close associations with Desuyo’s mother.

ISSUE

The sole issue for resolution is the identity of the perpetrator. The defense of alibi and mistaken identity is pitted against the victim’s positive identification.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s reliance on the victim’s credible testimony over the weak defense of alibi. The legal logic is anchored on the principle that positive identification, when categorical and consistent, prevails over alibi, which is inherently weak and easily fabricated. The Court found no reason to doubt Aileen Olisco’s identification. As the eyewitness, her recollection was deemed reliable, especially given the traumatic nature of the event, which would have etched the assailant’s face in her memory. Her identification from a photograph, in a line-up, and in open court was unwavering.
Conversely, the alibi defense was unconvincing and crumbled under scrutiny. The supporting testimonies were either inconsistent, irrelevant, or suspect due to the witnesses’ relationship with the accused’s family. Notably, one defense witness contradicted herself on a material date. The Court also viewed Desuyo’s additional allegation of police extortion as a preposterous and self-serving claim that further damaged his credibility. Since the defense failed to prove it was physically impossible for Desuyo to be at the crime scene, the alibi must fail. The affirmed penalty is reclusion perpetua, with an increase in moral damages to P30,000.00.