GR 45533; (November, 1977) (Digest)
G.R. No. L-45533 November 29, 1977
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS D. NAZARENO, defendant-appellant.
FACTS
Jesus D. Nazareno was convicted of rape and sentenced to reclusion perpetua. The complainant, Rayda Aumada, was a housemaid in Nazareno’s household from November 1969 to January 1971. She alleged she was raped twice in January 1970. She gave birth to a child on April 14, 1971, which she subsequently discarded. During a barrio investigation, she identified Nazareno as the father but did not initially mention force. A formal complaint for rape was filed only on May 5, 1971. Notably, the complainant did not report the alleged assaults to her sister, who also worked in the house, her parents, or Nazareno’s wife during her continued stay. Her pregnant condition also went unnoticed.
ISSUE
Whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted the appellant. The ruling was heavily influenced by a Manifestation from the Office of the Solicitor General, which recommended acquittal after a conscientious appraisal of the evidence, citing failure of proof. The Court emphasized the constitutional presumption of innocence, which must be overcome by proof beyond reasonable doubt. The complainant’s testimony was found inherently incredible on crucial points. A major inconsistency was the timeline: she claimed conception in late January 1970 but delivered in April 1971, a period of approximately fifteen months, which is biologically improbable for a human pregnancy. Her attempt to explain this by claiming an earlier birth in October 1970 only created further improbabilities. Her damaging admissions during cross-examination, including that she was not forced and that she consented because she “liked” the appellant, severely undermined the essential element of force or intimidation required in rape. The Court also noted her failure to disclose the alleged crime promptly to close relatives despite having the opportunity, which cast doubt on the veracity of her claim. The totality of the evidence created reasonable doubt. The Court, while sympathetic to the complainant’s situation, held that the rigorous standard for a criminal conviction was not met.