G.R. No. 93410 ; May 7, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO GODINES and DANNY MORENO, defendants-appellants.

FACTS

The appellants were convicted of forcible abduction with rape by the Regional Trial Court of Masbate and sentenced to reclusion perpetua. The prosecution’s evidence established that on March 17, 1988, appellants entered the house where complainant Esther Ancajas was staying. After assaulting the homeowners and taking money, they forcibly dragged Ancajas and her child to a nearby vacant lot. Armed and threatening to kill her, both appellants took turns in raping her while the other held her child. Ancajas reported the incident, and a medical examination revealed physical injuries consistent with sexual assault.
The defense interposed alibi, claiming they were attending a religious service and subsequently at a different location approximately two to three kilometers away, tending to an ill Godines. They asserted no prior ill motive against the complainant, whom they had known since childhood. The trial court rejected the defense, noting inconsistencies in their testimonies and emphasizing that alibi cannot prevail over the positive identification by the victim.

ISSUE

Whether the trial court erred in convicting the appellants of the crime charged and in rejecting their defense of alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court upheld the trial court’s assessment of credibility, ruling that the defense of alibi is inherently weak and cannot overcome the positive, clear, and convincing identification made by the victim. The distance of a few kilometers from the crime scene did not render it impossible for the appellants to have committed the offense. The Court found the medical evidence corroborative of the rape.
Regarding the nature of the offenses, the Court ruled that forcible abduction was absorbed by rape, as the abduction’s sole purpose was to commit rape. However, the evidence proved two distinct acts of rape committed in conspiracy. Under the rules, as the appellants failed to object to the single information charging the complex crime, they could be convicted of as many offenses as were proven. In conspiracy, the act of one is the act of all. Consequently, each appellant is guilty as a principal of two counts of rape—for the act he personally committed and for the act of his co-conspirator. The penalty was modified to life imprisonment for each count of rape for each appellant, with an increased indemnity.