G.R. No. 228960 . June 11, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JUNREL R. VILLALOBOS, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that on June 7, 2008, in Panabo City, AAA was sleeping with her children when an intruder, his face initially covered, entered her room, pointed a gun at her, and forced her to a nearby nipa hut. There, AAA recognized the accused-appellant, Junrel R. Villalobos, by his voice and later by his face when his mask was removed and by the moonlight. Villalobos, through force and intimidation, successively committed acts of rape by vaginal and anal penetration, and forced AAA to perform oral sex. AAA managed to escape when a vehicle’s light illuminated the area. She immediately reported the incident, and a medical examination confirmed recent sexual intercourse and physical injuries.
The defense presented an alibi. Villalobos denied the accusation, claiming he was asleep in his house at the time of the incident. He alleged the case was fabricated to extort money from him, a claim corroborated by his siblings who testified he was home all evening. The Regional Trial Court found Villalobos guilty of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua without eligibility for parole.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The Court held that the prosecution successfully proved Villalobos’s guilt beyond reasonable doubt. AAA’s positive identification of the appellant was credible, consistent, and unwavering. She recognized him by his voice during the initial encounter and clearly saw his face in the moonlight inside the hut, leaving no doubt as to his identity. Her detailed testimony on the sequence of sexual violations was corroborated by the medical findings. The defense of alibi, inherently weak, must yield to the positive identification by the victim. Alibi cannot prevail where the accused has been positively identified, especially when the defense fails to prove it was physically impossible for him to be at the crime scene.
Regarding the penalty, the Supreme Court modified the appellate court’s decision by deleting the qualification “without eligibility for parole.” The Court reiterated that under prevailing law and jurisprudence, when reclusion perpetua is imposed as a penalty for rape, it is understood to carry no eligibility for parole. The explicit phrase “without eligibility for parole” is only required when circumstances warranting the death penalty are present but its imposition is prohibited by law. No such qualifying circumstances were alleged or proven in this case. Thus, the proper penalty is reclusion perpetua. The Court affirmed the award of civil indemnity, moral damages, and exemplary damages to the victim.