G.R. No. 232455 , December 02, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. TEODORO ANSANO Y CALLEJA, ACCUSED-APPELLANT.

FACTS

The accused-appellant, Teodoro Ansano, was charged with the rape of AAA, a minor, on April 6, 2005. AAA testified that while she was on her way to fetch her father, Ansano, armed with a bolo, threatened to kill her and forced her to a secluded area. There, he undressed her, performed oral sex on her, and then had carnal knowledge of her twice. AAA, then 13 years old, reported the incident to her parents, who brought her for a medical examination. The medico-legal report confirmed fresh hymenal lacerations. AAA positively identified Ansano as her assailant over a year later when she saw him at her house and subsequently at the municipal hall.
The defense presented alibi and denial. Ansano claimed he was swimming with friends at the time of the incident and did not know AAA. He asserted that he had no scar on his face, contrary to AAA’s description. The Regional Trial Court found him guilty of rape, a decision affirmed by the Court of Appeals. Ansano appealed to the Supreme Court, arguing that AAA’s identification was unreliable and that his alibi should prevail.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, particularly regarding the reliability of the victim’s out-of-court identification.

RULING

The Supreme Court affirmed the conviction. The Court held that AAA’s positive identification of Ansano was credible and reliable. The totality of circumstances under the Biggers factors—the opportunity of the witness to view the criminal, the witness’s degree of attention, the accuracy of the prior description, the level of certainty at the confrontation, and the time between the crime and the confrontation—supported the identification’s trustworthiness. AAA had a clear, direct, and prolonged view of her assailant during the traumatic assault in daylight. Her detailed description, including facial features like a scar and being “singkit,” matched Ansano. Her identification, though made over a year later, was rendered with certainty.
The Court dismissed the defense of alibi as inherently weak and cannot prevail over the positive identification by the victim. The medical findings corroborated AAA’s testimony of sexual violation. The Court emphasized that the assessment of the trial court on witness credibility is accorded great respect. All elements of rape under Article 266-A of the Revised Penal Code were proven: carnal knowledge through force and intimidation, with AAA being a minor at the time. The penalty was modified to reclusion perpetua without eligibility for parole, and damages were awarded accordingly.