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PEOPLE v. ENDRIQUITO REYNALDO

FACTS:

In the case, the accused, Endriquito Reynaldo, was found guilty of the crime of rape. The victim, Anacyl Barrera, filed a complaint against him for raping her. The incident occurred on the evening of May 28, 1987, while Barrera was sleeping with her siblings in their house. The accused woke her up by pointing a knife at her and touching her breasts forcefully. He threatened to harm Barrera and her family if she made any noise or disclosed the incident. The accused then took her to their room, instructed her to undress, and raped her at knifepoint. After the assault, Barrera immediately informed her aunt about the incident. The aunt then reported the crime to the police and the accused was apprehended. Barrera underwent a medical examination, which showed signs of forced sexual intercourse. The accused denied the allegations and presented an alibi defense, claiming to be with someone else at the time of the incident. However, the trial court found Barrera and her aunt's testimonies credible, leading to the conviction of the accused for rape. The court sentenced him to reclusion perpetua and ordered him to pay an indemnity of Thirty Thousand Pesos (P30,000.00).

ISSUES:

  1. Whether the identity of the accused-appellant as the perpetrator of the crime has been established beyond reasonable doubt.

RULING:

  1. The Supreme Court found that the complainant's positive identification of the accused-appellant as the perpetrator was credible and trustworthy. The alleged contradictions in the complainant's testimony were deemed more imaginary than real and did not detract from her positive identification. The defense of alibi raised by the accused-appellant failed since it did not prove physical impossibility for him to be at the scene of the crime at the time of its commission.

PRINCIPLES:

  1. The testimony of a witness, when credible and trustworthy, is enough to establish the identity of the perpetrator of a crime.

  2. Identification can be made through various means including voice, physical features, and prior familiarity.

  3. The trial judge's assessment of a witness's credibility is given great weight on appeal.

  4. The defense of alibi must clearly prove that it was physically impossible for the accused to be at the scene of the crime.

  5. The presence of a deadly weapon in the commission of rape calls for the imposition of the penalty of reclusion perpetua.

  6. The absence of spermatozoa and lacerations does not necessarily negate the commission of rape; penetration, no matter how slight, is sufficient.

  7. Civil indemnity in rape cases is mandatorily awarded and has been increased to Fifty Thousand Pesos (P50,000.00) in accordance with jurisprudence.