G.R. No. L-34969 April 29, 1975
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AURELIO CUDALINA alias ORIL, defendant-appellant.

FACTS

On the night of November 1, 1970, in Cuyapo, Nueva Ecija, the accused, Aurelio Cudalina, arrived at the house of Asuncion Cachuela. After demanding wine and displaying a .45 caliber pistol, he left but returned past midnight. He forced Asuncion’s common-law husband, Ignacio Biag, to cook, and after Biag left the house, Cudalina approached Asuncion. He threatened her with his gun, tore her clothing, and forcibly had sexual intercourse with her despite her resistance. Afterward, he threatened to kill her and her children if she reported the incident.
Immediately after the assault, Asuncion sought help. The following morning, accompanied by a relative, she reported the rape to the barrio captain, showing her torn garments, and subsequently filed a formal complaint with the police. The prosecution presented Asuncion’s categorical testimony, corroborated by the barrio captain and the physical evidence of her torn clothing and the flashlight Cudalina left behind.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, overcoming his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the complainant, Asuncion Cachuela, to be credible, straightforward, and consistent. Her immediate act of reporting the crime to the barrio captain and the police, presenting her torn clothing as evidence, constituted a natural reaction consistent with an honest desire to seek justice, lending strong credibility to her account. The physical evidence corroborated her narrative of a violent assault.
The defense of alibi proffered by Cudalina was correctly rejected by the trial court. The Court reiterated the settled doctrine that alibi is inherently weak and cannot prevail over the positive identification of the accused by the victim. For alibi to succeed, the accused must demonstrate not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the scene. Cudalina’s claim of guarding a farm some distance away failed to meet this stringent requirement of physical impossibility. His defense was further weakened by the lack of credible corroboration and its inconsistency with the prosecution’s strong evidence. The trial court’s assessment of witness credibility is accorded great weight, and no compelling reason was shown to overturn its findings. The conviction for rape and the penalty of reclusion perpetua, including the award of indemnity, were thus upheld.