GR 116305; (July, 1998) (Digest)
G.R. No. 116305 July 2, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ENDRIQUITO REYNALDO alias QUITO, defendant-appellant.
FACTS
On the evening of May 28, 1987, sixteen-year-old Anacyl Barrera was sleeping in the sala of her house in Barangay Bambanan, Miagao, Iloilo, with her younger siblings. She was awakened when a knife was pointed at her and her breast was being mashed. The assailant threatened to kill her and her family if she made noise. He dragged her to a room, ordered her to undress, and, while pointing a knife at her, laid on top of her and inserted his penis into her vagina. She felt pain and lost consciousness. Upon regaining consciousness, the assailant was gone, and she noticed a whitish substance near her vagina. The next day, she reported the incident to her aunt, leading to the arrest of the accused, Endriquito Reynaldo, who was known to her as her uncle’s wife’s sister’s husband. A medical examination conducted on May 29, 1987, revealed no vaginal lacerations but noted a whitish discharge and resistance upon finger insertion. The doctor testified that the absence of lacerations or sperm did not negate rape. The accused pleaded not guilty and interposed an alibi, claiming he was in Barangay Kirayan, about eight kilometers away, at the time of the incident, a claim corroborated by a friend. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua and ordered him to indemnify the victim P30,000.00.
ISSUE
Whether the identity of the accused-appellant as the perpetrator of the rape has been established beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The alleged inconsistencies in the victim’s testimony regarding how she identified the accused (by voice, hairy arms, seeing his beard in the light, and touching his hand and face) were minor and did not affect her credibility. The Court held that such minor inconsistencies may even enhance credibility by showing the testimony was not rehearsed. The victim’s positive identification, given her familiarity with the accused over seven years, prevailed over the weak defense of alibi. The accused failed to prove it was physically impossible for him to be at the crime scene. The medical findings, explained by the doctor, did not disprove rape. The penalty of reclusion perpetua was affirmed. The civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence.