GR 131823; (January, 2001) (Digest)
G.R. No. 131823 . January 17, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISAGANI PARAISO y HUTALLA, accused-appellant.
FACTS
The accused-appellant, Isagani Paraiso, was charged with the crime of rape with homicide. The prosecution’s case rested primarily on the eyewitness account of Benny Reoveros. Reoveros testified that on August 5, 1994, in Macalelon, Quezon, he heard a child’s cries for mercy. Investigating, he saw Paraiso carrying the 13-year-old victim, Arlene Recilla. He witnessed Paraiso lay her down, remove her shorts, and rape her. Afterward, Paraiso hacked the victim on the neck with a bolo, causing her death. The post-mortem examination confirmed sexual abuse and that death resulted from multiple hack wounds.
The defense presented an alibi, claiming Paraiso was at home sleeping at the time of the crime, having returned from a drinking session with the victim’s father. The trial court, however, found the testimony of eyewitness Reoveros credible despite some inconsistencies on minor details like distances and cardinal directions. The court convicted Paraiso and imposed the death penalty, prompting this automatic review.
ISSUE
Whether the trial court erred in convicting the accused-appellant of rape with homicide based on the credibility of the prosecution’s eyewitness.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial judge’s assessment of witness credibility, emphasizing that minor inconsistencies in testimony regarding trivial matters do not undermine the witness’s core account but may even enhance credibility by showing a lack of rehearsal. The eyewitness positively identified Paraiso and gave a coherent, detailed narration of the rape and subsequent killing. His lack of formal education explained his difficulty with precise measurements and directions, which did not negate the substance of his testimony.
The Court found the alibi weak and unsubstantiated, as it was not physically impossible for Paraiso to have been at the crime scene. The medical evidence corroborated the eyewitness account. The qualifying circumstance of use of a deadly weapon was present, and the killing was committed by reason or on the occasion of the rape, constituting the special complex crime of rape with homicide. The penalty of death was proper under the law at the time. The civil indemnity was increased to P100,000.00 in line with prevailing jurisprudence.