G.R. No. 194234; June 18, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAYSON CRUZ y TECSON, Accused-Appellant.

FACTS

Accused-appellant Jayson Cruz was charged with rape under Article 266-A in relation to Article 266-B of the Revised Penal Code. The information alleged that on or about May 26, 2003, in Quezon City, Cruz, by means of force and intimidation, had sexual intercourse with AAA, a 15-year-old minor, against her will and without her consent. During trial, the prosecution presented AAA, who testified that on the evening of May 26, 2003, Cruz called her via her father’s cellphone, asking her to come to his house. After obtaining her mother’s permission, she went to Cruz’s residence. Upon arrival, Cruz’s friends left, and he forcibly pulled her into his bedroom, pushed her onto a bed, removed her shorts and panties, and inserted his penis into her vagina despite her pleas and resistance. After ejaculating on her leg, Cruz left her locked inside the house until she escaped the following day. AAA reported the incident to her family, and a medico-legal examination revealed deep-healed lacerations at 4:00 and 9:00 o’clock positions, indicating a non-virgin state. Cruz interposed the defense of alibi and denial, claiming AAA was his girlfriend who had proposed elopement and threatened to accuse him of rape after he refused. Defense witnesses corroborated his account. The Regional Trial Court (RTC) convicted Cruz of rape and sentenced him to reclusion perpetua, ordering him to pay indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction but increased the moral damages.

ISSUE

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

RULING

The Supreme Court REVERSED and SET ASIDE the decisions of the RTC and CA and ACQUITTED accused-appellant Jayson Cruz on the ground of reasonable doubt. The Court found lingering doubts inconsistent with the quantum of evidence required for conviction. Key inconsistencies and circumstances undermined AAA’s credibility: (1) It was puzzling why Cruz would call AAA using her father’s (a policeman) cellphone if he had criminal intent; (2) AAA’s testimony that the rape was her first sexual experience conflicted with the medico-legal finding of “deep-healed” lacerations, which suggested prior sexual activity; (3) AAA’s claim of being locked inside the house for a full day without escape attempts until Cruz used the comfort room was improbable, given opportunities to seek help from people outside; (4) The delay in reporting the incident to her mother, coupled with her initial silence, cast doubt on her narrative; and (5) The defense presented evidence, including letters and witness testimony, suggesting a romantic relationship and a motive for false accusation. The Court emphasized that while a rape victim’s testimony is often sufficient for conviction, it must be scrutinized with caution, and the prosecution’s evidence must stand on its own merits. Here, the inconsistencies and improbable details created reasonable doubt, warranting acquittal. Cruz was ordered immediately released unless held for other lawful causes.