GR 136594; (March, 2001) (Digest)
G.R. No. 136594 March 13, 2001
The People of the Philippines, plaintiff-appellee, vs. Joel Caniezo y Salazar, accused-appellant.
FACTS
On November 5, 1995, in Sta. Maria, Laguna, accused-appellant Joel Caniezo approached Sheila Aninao at her home, falsely stating that her friend had something to give her. With her mother’s permission, Sheila accompanied him to a house where he lured her inside. There, he threatened her with a bolo. Sheila managed to flee but tripped; Caniezo caught her, dragged her to a secluded citrus plantation, rendered her unconscious by knocking her head against a rock, and raped her. Upon regaining consciousness, she found herself naked and bleeding. Caniezo later escorted her to her godmother’s house, where she reported the assault. Medical examination confirmed recent sexual intercourse and physical injuries consistent with rape.
The defense presented an alibi, claiming Caniezo was in Tanay, Rizal, throughout that day, attending a birthday party and making charcoal. He denied knowing the victim or being in Laguna on the incident date, though he admitted knowing the victim’s mother through a mutual acquaintance. The trial court convicted him of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the guilt of accused-appellant Joel Caniezo for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Sheila Aninao, to be credible, straightforward, and consistent. Her detailed account of the deception, use of a bolo, the chase, the violent attack causing her unconsciousness, and the subsequent rape was corroborated by the medical certificate showing fresh hymenal lacerations and genital trauma. The defense of alibi was inherently weak and could not prevail over the positive identification by the victim. For alibi to succeed, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of being at the crime scene. Caniezo failed to prove this impossibility, as Tanay, Rizal, is not so geographically distant from Sta. Maria, Laguna, as to preclude his presence there on the day in question. The Court also noted the natural reaction of a rape victim to report the crime promptly, which Sheila did by immediately informing her godmother and mother. The award of damages was modified, adding P50,000.00 as civil indemnity and P20,000.00 as exemplary damages to the P50,000.00 moral damages awarded by the trial court.