G.R. No. 121765 March 14, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RANDOLF MONTEALTO y BOLDA, accused-appellant.

FACTS

On the evening of March 25, 1993, Mildred Hucamis was walking home along Buhangin Road in Davao City when accused-appellant Randolf Montealto suddenly grabbed her, pointed a knife at her neck, and dragged her to a grassy area. There, a second, unidentified slim man joined them. The accomplice took Mildred’s bag containing P100.00. Both men then raped her sequentially, with appellant also mashing her breasts. Afterward, they carried her back near the road, where she overheard appellant suggest killing her, but the accomplice dissuaded him. Mildred ran home, reported the rape to her aunt and mother, and immediately went to the police station and a medical center for examination.
Appellant was charged with robbery with rape. The prosecution’s case rested primarily on Mildred’s positive and detailed testimony, corroborated by her aunt, the police blotter, and the medical findings. Mildred identified appellant from a police “rogues’ gallery” of photographs. The defense presented alibi, claiming appellant was elsewhere at the time, and attacked the credibility of the prosecution’s witnesses, alleging inconsistencies and a suggestive identification process.

ISSUE

The core issue is whether the prosecution proved appellant’s guilt for the crime of rape beyond reasonable doubt, overcoming his defense of alibi and challenges to the victim’s identification and testimony.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Mildred’s credibility, finding her testimony clear, convincing, and consistent on material points. The alleged inconsistencies were minor and did not undermine the core narrative of the rape. The identification process was deemed reliable; Mildred had a clear view of appellant’s face under adequate lighting during the initial attack and later independently pinpointed his photograph from an array without improper suggestion from the police.
The defense of alibi was rejected. The Court reiterated the doctrine that alibi is inherently weak and cannot prevail over the positive identification of the accused by the victim, especially when the victim has no motive to falsely testify. For alibi to succeed, it must be demonstrated that it was physically impossible for the accused to have been at the crime scene. Appellant failed to meet this stringent requirement. However, the Court respected the trial court’s finding that only one count of rape committed by appellant himself was proven beyond reasonable doubt, due to lack of corroborative evidence for the other rape by the unidentified accomplice and the robbery. Thus, the penalty of reclusion perpetua and the award of moral damages were sustained.