GR 184812; (July, 2010) (Digest)
G.R. No. 184812; July 6, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. ERMILITO ALEGRE y LAMOSTE, Appellant.
FACTS
The prosecution established that the victim, VON, visited relatives at a house owned by appellant Ermelito Alegre on the evening of September 14, 2002. Alegre invited her for a drink and later to meet his girlfriends at a nearby abandoned house. Upon entering, VON found the house empty. When she attempted to leave, Alegre punched her, stabbed her multiple times with an ice pick, stripped her, and raped her. He inflicted further stab wounds before leaving her for dead. Severely injured, VON was found naked and bleeding by barangay officials in the early morning of September 15. Medical examination confirmed 18 stab wounds, including life-threatening injuries to her heart, and recent hymenal lacerations consistent with rape.
For his defense, Alegre claimed he was with VON only for a drink earlier that evening and then went home to sleep, presenting an alibi. He suggested VON fabricated the charges due to a past grudge involving her cousin. The Regional Trial Court convicted Alegre of frustrated murder and qualified rape, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s finding that the prosecution evidence sufficiently proved Alegre’s guilt for qualified rape and frustrated murder beyond reasonable doubt.
RULING
The Supreme Court denied the appeal and affirmed the convictions. The Court upheld the trial court’s assessment of VON’s credibility, which is generally accorded great weight and respect as the trial judge directly observed the witnesses’ demeanor. The Court found VON’s detailed and consistent account of the violent attack and rape to be credible and corroborated by the physical evidence, particularly the medical findings of multiple stab wounds and genital injuries. Her testimony remained steadfast despite rigorous cross-examination.
In contrast, Alegre’s defense of alibi was inherently weak and uncorroborated. The Court emphasized that alibi cannot prevail over the positive identification by the victim, especially when the defense fails to prove it was physically impossible for the accused to be at the crime scene. Alegre’s claim of a motive for fabrication was deemed insufficient to overturn the consistent factual findings of the lower courts. The Court modified the penalties by declaring Alegre ineligible for parole and increased the civil indemnity and moral damages for the rape conviction in accordance with prevailing jurisprudence.