G.R. No. 100586 , January 15, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DINDO CASTILLON and VALERIANO CABAJES, accused-appellants.

FACTS

Accused-appellants Dindo Castillon and Valeriano Cabajes were charged with multiple rape in two separate complaints sworn by Arlene Cabajes Devocion. This case concerns Criminal Case No. 287, which alleged that on February 27, 1987, at around 11:00 PM at the stage of Albor Municipal High School in Libjo, Surigao del Norte, the appellants, conspiring and using force and intimidation, had carnal knowledge of the complainant against her will. Upon arraignment, appellants pleaded not guilty. After a joint trial, the Regional Trial Court found appellants guilty of rape in Criminal Case No. 287, sentencing each to reclusion perpetua, and acquitted them in Criminal Case No. 288 for insufficiency of evidence. Appellants appealed the conviction.
The prosecution’s version, as summarized by the trial court, states that on the evening of February 27, 1987, during a Junior-Senior prom, complainant Arlene decided to go home alone at about 11:00 PM. She was met by appellant Dindo Castillon, her sweetheart, who invited her to talk. They proceeded to the municipal stage where they engaged in romantic advances and ultimately had consensual sexual intercourse. After Dindo finished, while still sitting on top of her, he called out to Valeriano Cabajes, saying, “Come here Bay, it’s now your turn.” Arlene tried to twist free, but Dindo held her hands. Valeriano then approached, boxed her thighs, and, while she was immobilized from pain, had sexual intercourse with her as she shouted for help. Dindo ran away during this act. Arlene went home, did not immediately report the incident due to threats, and only later filed complaints.
The defense presented a different account. They claimed that on the same evening, Dindo met Arlene as agreed, and they strolled to the school stage where they engaged in romancing and prepared for consensual sexual intercourse. Suddenly, three persons, including Valeriano Cabajes, lit a match near them. Both Dindo and Arlene stood up, put on their pants, and ran away. No rape by Valeriano occurred.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellants Dindo Castillon and Valeriano Cabajes are guilty of rape in Criminal Case No. 287.

RULING

The Supreme Court REVERSED and SET ASIDE the judgment of the trial court and ACQUITTED accused-appellants Dindo Castillon and Valeriano Cabajes on the ground of reasonable doubt.
The Court held that the prosecution failed to establish guilt beyond reasonable doubt. The complainant’s testimony was found to lack credibility and contained inherent inconsistencies on crucial points. Key discrepancies noted included: (1) Her testimony on direct examination that Dindo was still sitting on her when he called Valeriano, versus her cross-examination statement that Dindo had already stood up and was putting on his brief; (2) Her claim that she shouted “My Lord, help!” during the alleged assault by Valeriano, which was not heard by defense witnesses who were nearby, and her admission that her shout was not loud; (3) Her failure to report the incident immediately or show signs of distress to her landlord or parents, contrary to the natural behavior of a rape victim; (4) The absence of any physical injury or torn clothing, despite her claim of being boxed and forcibly held; and (5) The improbable setting of the alleged crime—a stage near an ongoing school event where people were present.
The Court emphasized that in rape cases, the complainant’s testimony must be clear, convincing, and free from material contradictions. The evidence for the prosecution must stand on its own merits and cannot draw strength from the weakness of the defense. Given the serious doubts cast on the veracity of the complainant’s account by the inconsistencies and the unnatural conduct following the alleged incident, the constitutional presumption of innocence prevailed. The Court suggested that the complaint may have been filed to salvage the complainant’s honor after she was discovered engaging in consensual pre-marital sex. Therefore, appellants were acquitted and ordered released unless held for another lawful cause.