G.R. No. L-31012, August 15, 1973
The People of the Philippines, plaintiff-appellee, vs. Arturo Carandang, Mario Buiser, Montano Caraan and Diomedes Estrella, defendants-appellants.

FACTS

The case stems from the robbery and rape of the spouses Eugenio Gutierrez and Socorro Familiar in their home in San Pablo City on November 28, 1968. While the family was at supper, armed men, their faces partly covered, entered the house. The assailants, identified by Gutierrez as appellants Arturo Carandang and Diomedes Estrella, ransacked the home, stole cash and valuables, and assaulted Gutierrez. Carandang then forcibly pulled Socorro Familiar to the kitchen and raped her. Subsequently, Estrella also raped her at gunpoint. A third appellant, Montano Caraan, was present and initially intended to do the same but desisted after Socorro’s pleas. The victims identified the voices of the fourth appellant, Mario Buiser, from below the house, urging the others to hurry. Gutierrez later surreptitiously followed the perpetrators and reported the crime to the barrio captain, identifying all four appellants, whom he knew as workers in a plantation he supervised.
The defense relied primarily on alibi. Appellant Carandang claimed he was at the house of Otilio Diones the entire evening, where his co-accused later visited before leaving. He asserted he was asleep when police arrived and that he was initially used as a guide before being detained. The other appellants presented similar defenses of being elsewhere. The trial court rejected these alibis, finding the positive identification by the victims credible.

ISSUE

The core issue is whether the trial court erred in convicting the appellants based on the credibility of the prosecution witnesses’ identification and in rejecting the defense of alibi.

RULING

The Supreme Court affirmed the convictions. The Court emphasized that the appeal essentially questioned the trial court’s assessment of witness credibility, a matter generally beyond appellate review unless certain exceptions exist, such as when the trial court overlooked material facts. No such exception was present here. The positive identification of the appellants by the victims, who knew them prior to the incident, was deemed clear and convincing. The Court found no reason to deviate from the trial judge’s findings, which were based on the witnesses’ demeanor on the stand.
The defense of alibi was correctly dismissed. Jurisprudence consistently holds that alibi is a weak defense and cannot prevail over positive identification, especially when the accused is known to the victim. The appellants failed to prove it was physically impossible for them to have been at the crime scene. The Court also upheld the finding of conspiracy among all four appellants. The acts of ransacking the house, the threats, and the coordinated execution of the crimes demonstrated a community of criminal purpose. Consequently, all were held liable as principals: Carandang and Estrella for Robbery with Rape, and Caraan and Buiser for the crime of Robbery. The penalties and indemnities imposed by the trial court were affirmed.