G.R. No. 111710 January 7, 1998
People of the Philippines, plaintiff-appellee, vs. Rogelio Abuan, accused-appellant.

FACTS

Accused-appellant Rogelio Abuan was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The information alleged that on or about April 8, 1992, in Barangay Bolo, San Jacinto, Pangasinan, he had carnal knowledge of Rosita Villanueva, then 13 years old, by means of force and intimidation. Rosita testified that on the evening of April 8, 1992, accused-appellant went to her house, woke her up, forced her to go with him to his house, and raped her in the kitchen after warning her not to tell anyone. She claimed she did not resist because “he has a big body.” After the act, accused-appellant’s wife arrived and found Rosita in the toilet; Rosita affirmed the act occurred, and the wife warned her not to report it. Rosita did not report the rape until July 1, 1992, during a barangay conference called due to rumors her sister Virgie Lyn had been raped by accused-appellant. She executed an affidavit on July 9, 1992, and filed a complaint on July 10, 1992. Her mother, Lorina Villanueva, testified about the barangay conferences and an offer by accused-appellant to pay P5,000.00, which they refused. Barangay Captain Federico Ronquillo testified about the complaint and blotter entry. Dr. Lilia Santos’s medico-legal examination on July 7, 1992, revealed healed hymenal lacerations and a negative vaginal smear for spermatozoa. The defense presented alibi: accused-appellant, his wife Avelina, and Teodoro Abuan testified he was in Baguio City selling mangoes from April 8 to April 15, 1992. Delia Villanueva Abuan, Rosita’s sister and accused-appellant’s daughter-in-law, testified that Rosita slept in their parents’ house on the night of April 8, 1992.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Rogelio Abuan for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED accused-appellant Rogelio Abuan on the ground of reasonable doubt. The Court held that the prosecution failed to meet the required standard for conviction. The testimony of private complainant Rosita Villanueva was found not to be clear, positive, convincing, and consistent with human nature. Specifically, her account of being forced from her parents’ house without any intervention from others was deemed incredible. The nearly three-month delay in reporting the alleged rape cast doubt on the veracity of her claim. The testimony of her sister Delia, who stated Rosita slept in their parents’ house on the night of the incident, further engendered doubt. While the defense’s alibi was not entirely satisfactory and there was a hint of an offer to pay, conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The State failed to prove guilt beyond reasonable doubt.