People v. Parilla
REITERATIONFacts
The Antecedents: Complainant Flora Batulan, 12 years old, was with her sister Corazon, cousin Alexander Cenita, and friend Juanito Lumuntad, delivering fish. On their way home at twilight, accused-appellant Wilfredo Parilla, 45 years old, carrying a scythe, threw stones at them. As the children ran, Parilla caught up with Flora, who was slower due to recent illness. He covered her mouth, threatened her, and took her to the bushes where he allegedly raped her, causing her to lose consciousness. Upon regaining consciousness, Flora was dragged by Parilla to a rubber tree, where he allegedly had carnal knowledge of her a second time. Flora reported the incident to her aunt and father upon arriving home. Procedural History: The Regional Trial Court of Davao, Branch III, convicted Wilfredo Parilla of Rape on two counts, sentencing him to reclusion perpetua for each count, to be served simultaneously, and to pay P20,000.00 as moral damages. Parilla appealed the decision. The Appeal: Appellant Wilfredo Parilla appealed his conviction, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the lower court erred in not considering his defense. He assailed the credibility of the prosecution witnesses, claiming it was too dark to identify him. He presented an alibi, stating he was drinking tuba with others at a "camarin" owned by his landlord, and imputed the crime to his cousin, Noling Dimpas.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt based on the evidence presented. Whether the lower court erred in not giving credence to the defense of alibi and the imputation of the crime to another person, thereby impacting the assessment of the accused-appellant's guilt.
Ruling
The appealed judgment of the Regional Trial Court is affirmed. Accused-appellant Wilfredo Parilla is found guilty of Rape on two counts, with the penalty of reclusion perpetua for each crime, to be served simultaneously, and to pay P20,000.00 in moral damages.
Ratio Decidendi
On Issue 1: The Court held that the guilt of the accused-appellant was proven beyond reasonable doubt. The positive identification of the appellant by the victim, Flora Batulan, and the two eyewitnesses, Corazon Batulan and Alexander Cenita, was found to be credible and sufficient. Flora knew the appellant as a neighbor, and the witnesses were able to see him clearly despite the twilight, even describing the color of his shirt, which contradicted the claim that it was too dark. The medical examination corroborated Flora's testimony by showing a ruptured hymen and loss of virginity. The Court found no ulterior motive for the witnesses to falsely accuse the appellant, thus their testimonies were given full faith and credit. On Issue 2: The Court found the appellant's defense of alibi and his imputation of the crime to his cousin, Noling Dimpas, to be unworthy of credence. The appellant's story that Noling Dimpas was present at the "camarin" but not revealed to the authorities was inconsistent. Furthermore, the witness presented to support the alibi, Danilo Ignacio, was himself a detainee and admitted to being told what to say in court, undermining his credibility. The Court also noted that Tomas Espillarga, who was allegedly with the appellant, was not presented as a witness. The "camarin" was also located in the same barangay as the crime scene, making it not physically impossible for the appellant to have been present at the time of the commission of the crime. Therefore, the alibi was untenable and did not overcome the strong evidence of guilt.
Main Doctrine
The Court affirmed that positive identification of the accused by the victim and eyewitnesses, when credible and uncontradicted, is sufficient to establish guilt beyond reasonable doubt. The defense of alibi, to be given weight, must not only be substantiated but must also demonstrate the physical impossibility of the accused's presence at the scene of the crime, a requirement not met by the accused in this case. The testimonies of child witnesses, when clear and consistent, are given full faith and credit.