G.R. No. L-63219 November 28, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAXIMO MALABAD, accused-appellant.

FACTS

The accused-appellant, Maximo Malabad, was convicted of rape by the Court of First Instance of Cagayan and sentenced to reclusion perpetua. The prosecution’s evidence established that on the evening of November 29, 1977, in Solana, Cagayan, the appellant, who is the uncle of the complainant Natividad Malabad, forcibly pulled her to the back of a school stage. There, he covered her mouth, forced her to lie down, removed her underwear, and had carnal knowledge of her against her will. Natividad, an orphan living with her brother, resisted and struggled but was overpowered. After the incident, she went home crying and later revealed the assault to her sister-in-law, Matea, who observed blood stains on her skirt.
The defense interposed was alibi, claiming the appellant was at his house, which was approximately 100 meters from the crime scene. The trial court rejected this defense, giving full credence to the complainant’s positive identification and detailed testimony. The court also noted the appellant’s flight a few days after the incident, evading arrest for months until he was found hiding in another house, which was considered indicative of guilt.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the complainant’s credibility, emphasizing that her testimony was clear, convincing, and consistent. It ruled that the defense of alibi cannot prevail over the positive identification by the victim. The Court found the alibi inherently weak, as the appellant’s claimed location did not preclude his presence at the crime scene. Furthermore, the Court dismissed the appellant’s speculative argument that the act could have been consensual, noting it was contrary to human nature and the character of an unsophisticated young girl to consent to intercourse with her uncle in such a manner and place.
The appellant’s flight and evasion of arrest were correctly considered by the trial court as a strong circumstance corroborative of guilt. The Supreme Court modified the judgment only by increasing the civil indemnity to P20,000.00, consistent with prevailing jurisprudence. The penalty of reclusion perpetua was affirmed, as all elements of rape under Article 335 of the Revised Penal Code were sufficiently established by the prosecution’s evidence.