G.R. No. 129297 ; March 17, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMULO SAN DIEGO y ESPIRITU, accused-appellant.

FACTS

On September 1, 1995, Ailene G. Ebreo boarded a tricycle driven by accused-appellant Romulo San Diego to look for a lost umbrella. Instead of taking her to her destination, he allegedly drove her to an uninhabited house in Morong, Rizal, locked her in a room, and at knifepoint, raped her that evening and again the following morning. Ailene testified she was held for 48 days, during which she accompanied accused-appellant on his tricycle routes, out of fear and a desire to gain his trust to facilitate escape. She was finally found by her parents on October 18, 1995, at a public market. A medical examination confirmed her non-virgin state but found no external signs of violence. By the time of her court testimony in February 1996, she was about six months pregnant.
Accused-appellant presented a starkly different narrative, claiming a consensual romantic relationship. He testified that Ailene voluntarily lived with him as his lover during the period in question, and they had sexual intercourse with her consent. He asserted that the rape charge was fabricated only after Ailene’s pregnancy was discovered and he refused her father’s demand for financial support, which included an alleged attempt to force her to abort the child.

ISSUE

Whether the guilt of accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted accused-appellant. The Court found the prosecution’s evidence insufficient to establish guilt beyond reasonable doubt. The core of the ruling hinged on the inherent incredibility of the complainant’s story and the failure to prove the essential element of force, intimidation, or lack of consent. The Court noted that Ailene’s behavior during the 48-day period was utterly incompatible with that of a rape victim held against her will. Her actions—freely accompanying accused-appellant in public, sitting with him on his tricycle in marketplaces, and failing to seize numerous opportunities to escape or seek help—defied human experience and ordinary reaction. This conduct created serious doubt that she was under constant threat or duress.
Furthermore, the Court found the delay in reporting the alleged crime significant. Ailene and her parents waited for days after her “rescue” before filing a complaint. This delay, coupled with the accused’s unrebutted testimony about the pregnancy and the subsequent demand for support, strongly suggested an ulterior motive for the charge. The medical findings, showing no signs of physical trauma, also failed to corroborate the alleged use of violent force. In rape cases, the testimony of the complainant must be credible, natural, convincing, and consistent with human nature. The prosecution’s evidence fell short of this standard, leaving reasonable doubt as to the occurrence of a forcible sexual assault. Consequently, the presumption of innocence prevailed.