G.R. No. 106233 ; January 29, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBINSON ESTRERA, accused-appellant.

FACTS

Accused-appellant Robinson Estrera was convicted by the Regional Trial Court of Danao City of the rape of his relative, Ester Estrera Mistula, and sentenced to reclusion perpetua. The prosecution’s evidence consisted of complainant’s testimony that on May 1, 1991, at around 10:00 a.m., while she was at the family farm, accused-appellant suddenly appeared, twisted her arm, poked a knife at her, threatened to kill her, pulled down her shorts and panty, and had carnal knowledge with her against her will. She testified she was a virgin and it took an hour and a half for the act to be consummated. Afterward, she lay on the ground for 20 minutes, saw blood, washed her panty, and initially kept quiet. She reported the rape on May 16, 1991, after learning accused-appellant had also molested her younger sister. A medical examination revealed healed hymenal lacerations but no abrasions or hematoma. The prosecution also presented testimony from the sister about molestation attempts and from a cousin about an alleged settlement offer from accused-appellant’s wife. The defense presented a different version, claiming complainant and accused-appellant were lovers who had consensual sexual intercourse on April 27, 1991, during a fiesta dance, and again on May 5, 1991. Accused-appellant’s wife corroborated this, testifying about the affair and a confrontation with complainant.

ISSUE

Whether the prosecution evidence was sufficient to prove the guilt of accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED accused-appellant. The Court found the prosecution evidence insufficient to overcome the constitutional presumption of innocence. Complainant’s testimony was deemed not credible and inconsistent with human nature. The Court noted several improbabilities: (1) the alleged rape took an hour and a half despite the use of a knife and lack of vigorous resistance; (2) complainant lay on the ground for 20 minutes afterward instead of immediately fleeing; (3) she washed her panty to hide evidence but later reported the rape; (4) the 15-day delay in reporting was not satisfactorily explained; and (5) the medical findings of healed lacerations but no abrasions or hematoma were inconsistent with a violent assault. The defense of a romantic relationship, supported by the wife’s testimony, cast doubt on the claim of force. The alleged offer of compromise by the wife could not be considered an admission of guilt by the accused. The prosecution’s evidence failed to meet the required standard of clarity and certainty for a rape conviction.