G.R. No. 127315. September 21, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAFAEL “Lito” BALDEVIESO, FAUSTO “Totoy” ESCALANTE and ROBERTO IMPERIAL NERI alias “Balbon,” accused-appellants.

FACTS

On April 16, 1994, around 5:30 a.m., 16-year-old Liza Margarejo was defecating in an open space near her house when a man suddenly punched her stomach and another forced a tablet into her mouth, causing her to lose consciousness. She regained consciousness in a hut with bamboo flooring, where she saw the three accused-appellants conversing. Another tablet was forced on her, causing her to faint again. Upon regaining consciousness, she found herself alone, left the hut, and eventually reached her grandmother’s house by 5:00 p.m. She and her father reported the incident to the police and underwent a medical examination. Dr. Perceverando Tangug found redness on her vulva, opining a blunt object like an erect penis probably caused it, but noted the hymen was intact and coitus was not consummated. An information for forcible abduction with rape was filed against the appellants. The trial court found the elements of forcible abduction and rape not proven but convicted the appellants of Serious Illegal Detention, sentencing them to reclusion perpetua, believing they forcibly took and restrained Liza for almost 12 hours. The appellants denied the charges, asserting alibi and claiming they were drinking together and had witnessed Liza with another person the previous evening.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellants are guilty of Serious Illegal Detention.

RULING

No. The Supreme Court reversed and set aside the trial court’s decision and acquitted the accused-appellants. The Court found that the charge of Serious Illegal Detention was not established. A close scrutiny of the complainant’s testimony revealed discernible and material inconsistencies and contradictions going to the core of her credibility. The trial court failed to consider the totality of the evidence impartially. The prosecution’s evidence did not measure up to the required quantum of proof beyond reasonable doubt. When reasonable doubt exists, the verdict must be one of acquittal. The accused-appellants were ordered immediately released from custody unless lawfully held for another cause.