G.R. No. L-32106 February 14, 1983
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AGUINALDO REANA alias PORTILLANO, defendant-appellant.

FACTS

On August 27, 1968, at around midnight, three armed men forcibly entered the house of Pio Pereda in Barrio Matataja, Mulanay, Quezon, by tearing a portion of its bamboo wall. Inside, they ransacked the premises and stole various items and cash totaling P1,622.60. Two female occupants, Concepcion Red and Jocelyn Red, who were sleeping in the house, were awakened, had their hands and mouths tied, and were then sexually assaulted. The victims later reported the incident, and medical examinations confirmed hymenal lacerations consistent with sexual intercourse and physical marks from being bound.
Appellant Aguinaldo Reana was subsequently arrested and positively identified by Concepcion Red as the man who raped her during the incident. At trial, Reana presented an alibi, claiming he was engaged in a gambling session elsewhere that night. The Court of First Instance of Quezon found him guilty beyond reasonable doubt of the complex crime of robbery with rape and sentenced him to reclusion perpetua, with an order to restitute the stolen property or indemnify Pio Pereda for its value.

ISSUE

The core issue is whether the trial court erred in convicting the appellant of robbery with rape based on the identification by the victim and the sufficiency of the evidence proving the elements of the crime.

RULING

The Supreme Court affirmed the conviction. The Court found no merit in the appellant’s contentions. Regarding identification, the Court held it was positive and credible. Concepcion Red testified that a lamp from an adjacent room provided sufficient illumination, allowing her to recognize the appellant during the assault. Her testimony was straightforward and consistent, and her subsequent identification of Reana during the investigation was unequivocal. The defense of alibi was properly rejected, as it could not prevail over this positive identification.
On the proof of the crime, the Court ruled that all elements of robbery with rape under Article 294(2) of the Revised Penal Code were established. The forcible entry, taking of personal property with intent to gain, and the commission of rape through force and intimidation were proven by the victims’ testimonies, corroborated by medical findings and the police report. The Court modified the trial court’s decision by ordering the appellant to additionally indemnify Concepcion Red in the sum of P5,000.00 as moral and exemplary damages. The penalty of reclusion perpetua was affirmed, as the rape was committed by a single person without the use of a deadly weapon, thus falling under the provision for robbery with rape without qualifying circumstances for the death penalty.