GR 95254; (July, 1992) (Digest)
G.R. No. 95254 July 21, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCOS ABUYAN, JR. Y UDARBE, defendant-appellant.
FACTS
The accused-appellant, Marcos Abuyan, Jr., was charged with two counts of rape committed against his first cousin, Gelen Udarbe, on November 1 and November 16, 1983, in Makati. Both were staying in the house of their aunt, Erlinda Pedrera. The informations alleged that the rapes were committed by means of force, threats, and intimidation with the use of a kitchen knife. Upon arraignment, Abuyan pleaded not guilty. After trial, the Regional Trial Court found him guilty beyond reasonable doubt of both crimes and sentenced him to reclusion perpetua for each count, with indemnity to the victim. The accused appealed, assigning errors on the credibility of the complainant’s testimony, the finding that rape was committed twice, and the finding of guilt beyond reasonable doubt.
ISSUE
The core issue is whether the trial court erred in convicting the accused-appellant of two counts of rape based on the complainant’s testimony, thereby rejecting the defense of alibi and finding guilt beyond reasonable doubt.
RULING
The Supreme Court affirmed the trial court’s decision. The Court held that the trial court’s assessment of the complainant’s credibility is entitled to great weight and respect, as trial courts are in a better position to evaluate testimonies. The complainant’s detailed and consistent narration of the two rape incidents, including the use of a knife, force, and intimidation, was found credible. The Court rejected the defense of alibi, noting that the distance from the accused’s place to San Fernando, Pampanga, was not physically impossible to traverse, making his presence at the crime scene possible. The alibi defense was further weakened by the complainant’s positive identification of the accused, with whom she had been living. The Court also found no merit in the claim that rape was impossible due to other people in the house, as the prosecution presented evidence that the house owners were absent during the first incident and that other alleged occupants did not live there. The absence of motive for the complainant to falsely accuse the accused supported the finding of guilt beyond reasonable doubt. The penalty of reclusion perpetua for each count and the indemnity were affirmed.