GR 114972; (January, 1996) (Digest)
G.R. No. 114972; January 24, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FERNANDO CASTAĂ‘EDA Y SALES, accused-appellant.
FACTS
Accused-appellant Fernando Castañeda was convicted by the Regional Trial Court of Capas, Tarlac, for the crime of Robbery with Rape. The prosecution evidence established that on the evening of June 12, 1992, private complainant Eugenia Sese was at her home in Concepcion, Tarlac. While she was outside her house, a man approached, grabbed her, poked a knife at her throat, and demanded money. He forcibly dragged her inside, where she handed over P200.00. Subsequently, at knifepoint, he ordered her to pull down her pants and raped her. After the incident, the man threatened to kill her if she reported it. Later that night, while accompanied by barangay officials to the police station, Sese saw and identified Castañeda as her assailant near the boundary of Barangays San Jose and Sta. Maria.
The defense presented an alibi. Castañeda claimed he was at a birthday party in Barangay San Jose from 5:00 PM until midnight, serving guests and drinking. He stated he was accosted while walking near a bridge after the party. His employer and a relative corroborated his presence at the party. A barangay tanod also testified that Sese initially described a different suspect.
ISSUE
Whether the trial court erred in convicting accused-appellant of Robbery with Rape based on the identification by the private complainant and in rejecting his defense of alibi.
RULING
The Supreme Court affirmed the conviction. The Court found the positive identification by the private complainant to be credible and convincing. She had a clear view of the assailant’s face under the illumination of three kerosene lamps inside her house when she opened the aparador to get the money. Her subsequent identification of the accused-appellant later the same night was spontaneous and unequivocal. The alleged inconsistencies in her testimony, such as the non-presentation of the stolen money and the knife or the precise type of knife used, were deemed inconsequential. The failure to recover these items does not undermine her credible testimony, and the exact classification of the weapon is immaterial to establishing the element of intimidation.
The defense of alibi was rightly rejected. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene. Castañeda failed to meet this burden. By his own admission, he was within the vicinity, and Barangay San Jose was merely three kilometers away from the crime scene—a distance easily traversable in a short time. His claim of intoxication did not make his presence at the locus criminis impossible. The trial court’s assessment of the witnesses’ credibility is accorded great respect, and no compelling reason was found to overturn its findings. The crime of Robbery with Rape was thus proven beyond reasonable doubt.