G.R. No. 74952, March 12, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BERLY DALINOG, defendant-appellant.

FACTS

On February 27, 1982, in Sitio Dolao, Balud, Masbate, Cerlina Armenton, a woman in her ninth month of pregnancy, went to fetch water from a well. While there, she was attacked by her second cousin, Berly Dalinog. He grabbed her, pushed her to the ground, and forcibly had sexual intercourse with her despite her shouts and struggles. After the act, Dalinog threatened to kill her and her family if she reported the incident. The victim’s aunt, Linda Magno, heard the shouts and, upon approaching, saw Dalinog hurriedly leaving the scene and found Cerlina crying, with a torn dress and contusions. The incident was reported to barangay officials and subsequently to the police. A medical examination confirmed recent sexual intercourse and physical injuries consistent with a struggle.
The accused-appellant, Berly Dalinog, was charged with rape. He initially evaded arrest by allegedly bribing a serving officer. Upon arrest and arraignment, he pleaded not guilty. During trial, the defense presented an alibi, claiming Dalinog was in another municipality at the time. The trial court found the prosecution’s evidence credible, convicted Dalinog of rape, and sentenced him to reclusion perpetua. He appealed, challenging the credibility of the victim’s testimony.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the victim’s testimony and the corroborating evidence.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. The victim’s account was clear, consistent, and credible. She provided detailed testimony on the forcible assault, which was corroborated by her immediate outcry, the physical injuries documented in the medical certificate, and the testimony of her aunt who witnessed the aftermath. The Court found no ill motive for the victim, a married pregnant woman, to falsely accuse a relative of such a grave crime, which would expose her and her family to public scandal.
The Court rejected the defense of alibi as inherently weak and unsubstantiated. For alibi to prevail, it must be demonstrated that the accused was so far away that it was physically impossible for him to be at the crime scene. The defense failed to meet this burden. Furthermore, the trial court’s factual findings on witness credibility are accorded high respect and finality, as it is in the best position to observe demeanor. The Court found no cogent reason to overturn these findings. The penalty of reclusion perpetua was proper under Article 335 of the Revised Penal Code. However, the Court modified the decision to award civil indemnity to the victim in the amount of P30,000.00.