G.R. No. L-67598 October 11, 1985
The People of the Philippines, plaintiff-appellee, vs. Jesus Canturia y Dejita, accused-appellant.

FACTS

The accused, Jesus Canturia, was charged with the rape of Lani M. Nocete. The information alleged that on November 10, 1982, at around 3:00 AM in Daraga, Albay, the accused, armed with a deadly weapon, entered the complainant’s house while she was alone with her young children, and by means of force and intimidation, succeeded in having carnal knowledge of her. The accused pleaded not guilty. After trial, the Regional Trial Court of Legazpi City found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, with an order to indemnify the offended party.
The prosecution evidence established that the complainant, a married woman, was sleeping when an intruder entered her home, pointed a bladed weapon at her neck, and threatened that he had companions surrounding the house before raping her. She was able to see his face by the light of his flashlight and notably observed a tattoo on his left arm below the shoulder, which she read as “Vidal.” Following her report, a barangay official, after gathering information, located the accused at a local theater. The complainant positively identified him there, and police officers confirmed the presence of a tattoo on his left arm, which read “NIDAD.”

ISSUE

The core issue revolves around the credibility of witnesses and the sufficiency of the complainant’s identification of the accused as her assailant.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s assessment of witness credibility. The Court emphasized that the trial judge is in the best position to evaluate the demeanor of witnesses, and its findings are generally accorded great respect. The complainant testified in a straightforward and credible manner, and she had no discernible motive to falsely accuse a total stranger. Her positive identification was deemed reliable and was corroborated by the physical evidence of the tattoo on the appellant’s arm.
The Court found the discrepancy between the tattoo inscription reported by the victim (“Vidal”) and the actual tattoo (“NIDAD”) to be inconsequential under the circumstances. The traumatic event, coupled with the limited lighting, accounted for the minor variance, and the substantial identity of the distinguishing mark fortified her identification. Conversely, the appellant’s defense of alibi was rejected. His claim of being at his own house in the adjacent barangay at the time of the crime was uncorroborated. Furthermore, for alibi to prevail, it must be demonstrated that it was physically impossible for the accused to have been at the crime scene. Given that Barangay Sipi and Barangay Quimantong are adjacent, no such impossibility existed. The defense thus failed to cast reasonable doubt on the prosecution’s evidence. The appealed judgment was affirmed with the modification of increasing the civil indemnity to P20,000.00.