G.R. No. 102978 January 18, 1993
People of the Philippines, plaintiff-appellee, vs. Reynaldo Morre y Banequit, @ “Rey”, @ “Jimmy Boy”, @ “Naldo”, accused-appellant.

FACTS

The accused-appellant, Reynaldo Morre, was convicted of rape by the Regional Trial Court of Cebu City and sentenced to reclusion perpetua. The complaint alleged that on August 8, 1983, in Cebu City, the accused, with the use of a knife, had sexual intercourse with complainant Maria Sadani Nabua against her will. The accused pleaded not guilty. The trial was conducted by Judge Lauro V. Francisco, but the decision was written by Judge Meinardo P. Paredes, who did not observe the witnesses’ demeanor. The prosecution’s case relied heavily on the complainant’s testimony, which detailed that after a dance, she was met by her sweetheart, Dado Repolo, who introduced her to the accused and two others. The accused then covered her mouth, pointed a knife at her, and accosted her boyfriend. He brought her to multiple locations (a fence, a bamboo bed under an uninhabited house, a garden, and a chapel), kissed various parts of her body, and had sexual intercourse with her twice, threatening her with the knife when she resisted. She escaped when he fell asleep. The defense presented the accused’s testimony denying the rape. He claimed that on the night in question, he was drinking with friends when the complainant passed by with her boyfriend, Rene. He testified that he witnessed an argument where the boyfriend slapped the complainant. The defense also suggested improper motives, including an attempted extortion of P5,000 from the accused and retaliation by barangay officials. The accused escaped from detention after nearly two years, citing repeated mauling and medical treatment.

ISSUE

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

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED the accused-appellant on the ground of reasonable doubt. The Court emphasized that in rape cases, the complainant’s testimony must be scrutinized with extreme caution, and the prosecution’s evidence must stand on its own merit. Given that the judge who decided the case did not hear the witnesses testify, the Court conducted an independent evaluation. The Court found the complainant’s testimony lacking in credence. It noted inconsistencies and improbabilities, such as the lack of shouting for help in a reportedly lighted area, the prolonged and multiple acts in different locations without effective resistance, and the corroboration of the defense’s claim of a prior altercation by the medical findings of physical injuries on the complainant. The Court held that the accused’s escape, given the circumstances of his detention and maltreatment, did not conclusively prove guilt. While the defense was weak, the prosecution’s evidence was even weaker and failed to meet the required standard of proof beyond reasonable doubt. The constitutional presumption of innocence must prevail.