G.R. No. 138805 . February 28, 2001.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO MACEDA, accused-appellant.

FACTS

The prosecution established that on February 19, 1998, in Quezon City, accused-appellant Edgardo Maceda raped his neighbor, Maribeth Quinto, a 32-year-old mental retardate. Maribeth was alone in her house when Maceda knocked, entered, forced her to lie down, and had carnal knowledge with her against her will. She reported the assault to her mother the next day, leading to a medico-legal examination which revealed an abraded posterior fourchette, congested vestibule, and deep-healed hymenal lacerations, consistent with recent sexual intercourse. The prosecution presented the testimonies of the victim and her mother, alongside the medical findings.
The defense interposed denial and alibi. Maceda claimed he was asleep in his house at the time of the incident, a testimony corroborated by his sister and a cousin. His sister specifically testified that she locked the main door of their house each night and that no one could leave without her key, asserting it was impossible for Maceda to have left.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty from death to reclusion perpetua. The Court found the testimony of the victim, Maribeth Quinto, to be credible and consistent. As a mental retardate, her straightforward narration of the traumatic event, including the force employed and her resistance, carried great weight. The medical findings, while indicating she was no longer a virgin, corroborated the fact of recent sexual intercourse. The defense of alibi was rejected as inherently weak and insufficient to overcome the positive identification by the victim. The Court held that for alibi to prosper, it must be demonstrated that the accused was at such a distance that he could not have been physically present at the scene of the crime. Here, the defense merely established that he was allegedly at home, a mere 35 meters away, which did not constitute physical impossibility. The testimony of the sister regarding a locked door was deemed unconvincing and self-serving. Consequently, the trial court’s factual findings on credibility were upheld. However, the death penalty was reduced to reclusion perpetua as the information did not allege the victim’s mental retardation as a qualifying circumstance, which is necessary for imposing the supreme penalty under the law.