G.R. No. 108873 . December 4, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LAURENCE “LARRY” CAJILO and ROMER “GARY” MORGADO, accused-appellants.

FACTS

The accused-appellants, Laurence Cajilo and Romer Morgado, were convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The complainant, Andrea Itucas, testified that on March 14, 1992, the appellants, who were known to her, offered her a ride in a tricycle. They proceeded to the Dalampasigan Hotel under the pretext of a private conversation. Once there, they led her to a room where she was allegedly dragged inside, forcibly undressed, and sexually assaulted by Cajilo while Morgado held her down and mashed her breasts. She reported the incident immediately, and a medical examination confirmed fresh hymenal lacerations.
The defense presented a starkly different account. They claimed the sexual intercourse was consensual, alleging that Andrea was a former girlfriend of Cajilo and that they had gone to the hotel for a tryst. They asserted that Andrea demanded money afterward, and when Cajilo refused, she threatened to file a rape case. The defense also contended that the trial judge was biased, citing various procedural rulings against them.

ISSUE

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

RULING

The Supreme Court reversed the conviction and acquitted the accused-appellants on the ground of reasonable doubt. The Court found the complainant’s testimony lacked the requisite credibility and consistency to sustain a conviction. Her actions preceding the alleged rape were deemed incompatible with the behavior of someone about to be assaulted; she voluntarily accompanied the appellants to a secluded hotel, did not attempt to escape during multiple opportunities, and her claim of being dragged was inconsistent with the lack of external physical injuries noted in the medical certificate.
The Court emphasized that in rape cases, the accusation must be supported by credible and convincing testimony. Here, the evidence failed to establish moral certainty that force or intimidation was employed and that carnal knowledge occurred against the victim’s will. The medical findings, while indicating recent sexual activity, did not by themselves prove lack of consent. The defense of consensual intercourse, coupled with the questionable motives raised, created reasonable doubt. The Court clarified that the acquittal was based on the insufficiency of evidence, not on the alleged bias of the trial judge, whose actions were viewed as efforts to expedite the proceedings.