G.R. No. L-36790 May 29, 1987
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE INOT, defendant-appellant.

FACTS

The accused, Felipe Inot, was charged with rape. The Information alleged that on August 29, 1971, in Bogo, Cebu, he entered the house of Flora Noveranes at night and had carnal knowledge with her while she was asleep and unconscious, against her will. The prosecution’s evidence established that Flora was asleep alone in her house when a man got on top of her. Believing him to be her husband, she responded to the sexual act. Only after the act, when she embraced the man and felt his right arm amputated from the elbow, did she recognize him as Felipe Inot, their neighbor. She confronted him, he fled, and she immediately reported the incident with her husband.
The defense interposed alibi, claiming Inot was drunk and asleep in his own house, located about 20 meters away, at the time of the incident. He also assailed the credibility of Flora’s testimony, pointing to an alleged inconsistency: she stated she held both of the man’s arms during the act, yet the accused has a severed right arm. The trial court convicted Inot of rape and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused beyond reasonable doubt, particularly in light of the challenged credibility of the complainant’s testimony and the defense of alibi.

RULING

The Supreme Court affirmed the conviction. On the credibility of the complainant, the Court found no fatal inconsistency. The fact that Flora held the man’s arms during the sexual intercourse does not preclude the assailant from being Inot. The Court explained that an arm consists of an upper and lower portion; she could have grasped the upper arms, including the right upper arm (from shoulder to elbow), which Inot still possessed, thereby not detecting his deformity during the act. Her belief that it was her husband and her tired state from the day’s work further explained her initial lack of awareness.
Regarding the defense of alibi, the Court reiterated it is one of the weakest defenses. To prosper, it must be shown that the accused was at another place for such a duration that it was physically impossible for him to be at the crime scene. This was not established. The proximity of Inot’s house, merely 20 meters away, made it not only possible but easy for him to have gone to the victim’s house, committed the crime, and returned. His positive identification by the victim, who recognized his voice and distinctive physical defect, rendered the alibi untenable. The Court also held that a medical certificate is not indispensable for a rape conviction and that consent given under the mistaken belief the assailant was her husband is vitiated. The decision was affirmed with the modification of increasing the civil indemnity to P20,000.00.