G.R. No. 248202 - People vs. Macalindong y Andallon

On the night of May 2, 2011, private complainant AAA was in her residence with her children, househelper, and niece.
At early dawn, she was first disturbed by the dog barking and, upon checking, found no intruder.
Shortly thereafter, she was awakened when a masked man touched her shoulder and held a firearm to her neck, threatening her life if she resisted.

The masked assailant identified himself by voice as Joselito Bringcula y Fernandez after threatening her.
He ordered AAA to lie face down and proceeded to hogtie her with a shoelace.
He then stole jewelry and personal property, including two bracelets, a wedding ring, a necklace, two cellular phones, and cash, from the victim’s possession.
After gathering the valuables, he further escalated the crime by removing AAA’s pajama and underwear, then undressing himself to reveal his identity.
The assailant then committed rape by licking AAA’s vagina, kissing her neck, lying on top of her, and forcibly inserting his penis into her vagina.
AAA was prevented from calling for help due to the assailant’s threats of killing her.

Once the assailant left, AAA awakened her niece and eventually reported the incident to the police station in the morning.
She also submitted herself for a medical examination to document the injuries and the assault.
Based on her prompt report and the subsequent investigation, an Information was filed against the appellant for committing robbery with rape under Article 294(1) of the Revised Penal Code.

The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt of the special complex crime of robbery with rape.
The court sentenced the appellant to suffer reclusion perpetua, recognizing no mitigating or aggravating circumstances except the inherent aggravation provided by the location of the crime.
The judgment also imposed additional penalties: actual damages, moral damages, exemplary damages, and the award of restitution as civil indemnity.

The CA affirmed the RTC decision with modifications, particularly increasing the amount of the civil indemnity to P75,000.00, with an order for the appellant to pay interest on all awarded damages.
The CA held that the elements of the crime were satisfactorily established by the evidence, notably through AAA’s direct and credible testimony.

The appellant denied the allegations and asserted an alibi, stating that he was at home sleeping during the incident, a claim corroborated by his wife’s testimony.
He also questioned the credibility of AAA’s testimony due to alleged inconsistencies and the delay of her disclosure, as well as the legality of his warrantless arrest.

Whether the evidence on record sufficiently established the elements of the crime of robbery and rape beyond reasonable doubt.
Whether the testimony of the victim, despite any minor inconsistencies, was credible enough to support a conviction.

Whether AAA’s account, with its detailed narrative of the assault and robbery, could be relied upon despite the delay in immediately disclosing her assailant’s identity.
Whether inconsistencies in minor details could undermine the overall reliability of her testimony.

The validity of the appellant’s claim of alibi, supported by his wife’s corroborative testimony.
The contention that his identity was not properly established by the evidence presented.
The challenge to the legality of his warrantless arrest and whether procedural defects in the arrest could be grounds for reversal of the conviction.