G.R. No. 209584 , March 03, 2021
People of the Philippines, Plaintiff-Appellee, vs. Judito Coritana and John Doe, Accused, Judito Coritana, Accused-Appellant.

FACTS

Accused-appellant Judito Coritana and an unidentified old man (John Doe) were charged with the special complex crime of robbery with rape. The prosecution evidence established that on March 3, 2001, at around 5:00 a.m., the victim AAA was alone in the eatery where she worked. Two men, identified by AAA as Coritana (whom she knew as a resident of a nearby sitio) and an old man armed with a short bolo, entered. The old man threatened AAA with a knife. Coritana closed the eatery’s door and took money from the cash drawer. The old man then forced AAA into a small bathroom, tied and blindfolded her, bent her over, and raped her. Afterwards, the old man called Coritana, who also raped AAA in the same manner. The perpetrators then left, taking additional items including bags containing money. AAA reported the incident, was medically examined, and her injuries and the presence of spermatozoa were confirmed. Coritana was arrested on March 10, 2001. The defense presented an alibi, claiming Coritana was a pedicab driver at his brother’s house during the incident. The Regional Trial Court found Coritana guilty beyond reasonable doubt of robbery with rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Judito Coritana for the crime of robbery with rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications to the damages. The Court held that all elements of robbery with rape were proven beyond reasonable doubt. The taking of property was accomplished through violence and intimidation against AAA. The property belonged to another, and the taking was done with intent to gain. The rape was committed by reason or on the occasion of the robbery. The Court found AAA’s positive identification of Coritana credible, noting her prior familiarity with him as a resident of the adjacent sitio and her opportunity to see him before the attack. The defense of alibi was weak and could not prevail over positive identification. The Court also addressed the civil liability. It affirmed the awards for civil indemnity, moral damages, and exemplary damages for the rape. For the robbery, the Court awarded actual damages for the amounts proven to have been taken: P1,100.00 from the eatery’s drawer, P200.00 from AAA’s bag, and P1,800.00 from Teresita’s bag, totaling P3,100.00. All monetary awards shall earn legal interest at 6% per annum from the finality of the decision until fully paid.