G.R. No. 144161 . March 12, 2002.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAXIMO CRISTOBAL Y NORA alias “TOTOY”, accused-appellant.

FACTS

The prosecution evidence established that in the early morning of June 3, 1999, in San Mateo, Rizal, accused-appellant Maximo Cristobal entered the house of complainant Maria Juana del Rosario. While her husband and children slept nearby, Cristobal, armed with a kitchen knife, threatened to kill her and her family if she made noise. He then proceeded to have carnal knowledge of her against her will. The act was interrupted when the complainant’s head accidentally bumped her son Jasfer’s foot, awakening him. Upon seeing Jasfer stand up, the naked intruder fled through a window. The complainant reported the incident and identified Cristobal, her mother’s cousin’s husband, as her assailant. Medical examination revealed injuries consistent with sexual assault and physical force.
The defense interposed alibi and denial. Accused-appellant claimed he was at home with his family at the time of the incident. His wife corroborated his testimony. He argued that the complainant’s initial failure to immediately identify him to her husband and the barangay tanod, coupled with the lack of vigorous resistance during the alleged rape, cast doubt on the prosecution’s narrative.

ISSUE

Whether the guilt of accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, emphasizing that the matter of assigning values to testimonies is best performed by the trial court which observed the witnesses’ demeanor. The complainant’s positive identification of the accused-appellant, whom she knew prior to the incident, was categorical and credible. Her failure to shout or immediately reveal his identity to her husband was satisfactorily explained by her reasonable fear for her family’s safety due to the knife-point threat, which also accounted for her subdued resistance. The medical findings corroborated her account of a forcible sexual assault.
The defense of alibi was correctly rejected. For alibi to prosper, the accused must demonstrate not only his presence elsewhere but also the physical impossibility of his being at the crime scene. Here, accused-appellant’s house was a mere 15 meters away, rendering his presence at the locus criminis not impossible. Furthermore, alibi becomes inherently weak when established solely by the accused and his relatives, as in this case, and cannot prevail over the positive identification by the victim. The Court modified the damages, awarding civil indemnity ex delicto of P50,000.00 in addition to the moral damages.