G.R. No. L-42256 December 19, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DEMETRIO PIELAGO and GAUDENCIO TABAYAG, accused-appellants.

FACTS

On the evening of September 18, 1964, while Jose Quino and his family were having supper at their home in San Jose, Oas, Albay, several armed men, including Darwin Veloso and Gaudencio Tabayag, entered. Veloso and Tabayag tied up Jose Quino, his wife Felicidad Manzano, and his mother. The robbers demanded a gun, assaulted Quino upon his initial denial, and subsequently ransacked the house, stealing cash and valuables amounting to P2,285.00. Thereafter, Felicidad Manzano was dragged into a room and successively raped by Darwin Veloso and Gaudencio Tabayag, while being held by another accomplice. She positively identified the appellants, noting that their masks were pulled down. Demetrio Pielago was identified as acting as an armed lookout outside the house.
Appellants Tabayag and Pielago denied involvement, interposing alibi as their defense. Tabayag claimed he was arrested for drunkenness and confined in the Baao, Camarines Sur municipal jail on the exact evening of the crime. Pielago asserted he was at his home in Paulba, Ligao, Albay, approximately one kilometer away. Their co-accused, Darwin Veloso, corroborated their non-participation, naming different individuals as his companions. The trial court convicted them of Robbery with Rape, sentencing them to reclusion perpetua.

ISSUE

The core issue is whether the trial court erred in convicting the appellants based on the positive identification by the victims, despite their defenses of alibi and the alleged lack of medical evidence for the rape.

RULING

The Supreme Court affirmed the conviction, with a modification increasing the civil indemnity for rape to P30,000.00. The Court upheld the trial court’s assessment of the witnesses’ credibility. The positive, categorical, and consistent identification of both appellants by victims Jose Quino and Felicidad Manzano prevailed over their weak alibis. For Tabayag, the claim of being in jail was unsupported by credible evidence like a police blotter and was directly contradicted by the victims’ testimonies. For Pielago, his uncorroborated claim of being one kilometer away failed to demonstrate the physical impossibility of being at the crime scene. The Court emphasized that alibi must prove it was physically impossible for the accused to be present, which was not established here.
Regarding Tabayag’s argument on the corpus delicti of rape, the Court ruled that a medical examination is not indispensable for a rape conviction. The clear, convincing, and straightforward testimony of the victim, detailing the sexual assault, is sufficient to establish the crime. The Court noted that minor inconsistencies in the victims’ testimonies on peripheral details actually bolster their credibility, showing an absence of rehearsed narration. No ill motive was shown for the victims, particularly Quino who is Pielago’s cousin, to falsely implicate the appellants in such a grave crime. Thus, the findings of the trial court were sustained.