GR 122479; (December, 2000) (Digest)
G.R. No. 122479 ; December 4, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELLESOR T. SALAZAR, accused-appellant.
FACTS
Accused-appellant Ellesor T. Salazar was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The prosecution alleged that on February 18, 1992, Salazar and his brother Ramil (at large) conspired to rape Ofelia Cordeta. Ofelia testified that Salazar invited her and her boyfriend, Rolando Arcena, to a party at his house. After being served beer, she became dizzy. Salazar then brought her to a room upstairs, pushed her onto a bed, and had sexual intercourse with her despite her resistance. She claimed Ramil later entered the room armed with a knife, but she passed out. Rolando corroborated attending the party and their intoxication but testified he fell asleep in a separate room and later found Ofelia sleeping beside him, still clothed, with no signs of distress. He also presented medical evidence that he was circumcised a week prior and could not have performed sexual intercourse.
ISSUE
Whether the guilt of accused-appellant Ellesor T. Salazar for the crime of rape was proven beyond reasonable doubt.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant based on reasonable doubt. The Court found the prosecution’s evidence insufficient and fraught with inconsistencies. Critical to the reversal was the testimony of Rolando Arcena, the victim’s boyfriend and an eyewitness to the events leading to the alleged crime. His account directly contradicted Ofelia’s version, as he found her peacefully sleeping and fully clothed the morning after. His testimony was bolstered by medical certification that his recent circumcision physically prevented him from sexual activity, negating any possibility he was the perpetrator, which the defense suggested as a motive for Ofelia’s accusation. The Court emphasized that in rape cases, the conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The complainant’s testimony failed to meet the test of credibility due to these material inconsistencies and the lack of corroborative evidence. The presence of reasonable doubt arising from these conflicting narratives and the physical evidence mandated an acquittal.