G.R. No. 106274 September 28, 1993
People of the Philippines, plaintiff-appellee, vs. Henry Padero, accused-appellant.

FACTS

Accused-appellant Henry Padero was charged with the rape of his sixteen-year-old niece-in-law, Jocelyn Cadeliña, on or about August 31, 1991, in Bais City. The complaint alleged that Padero, armed with a knife and by means of force and intimidation, had carnal knowledge of the complainant against her will. The Regional Trial Court convicted Padero of rape and sentenced him to reclusion perpetua and an indemnity of P30,000. Padero appealed the decision.
The prosecution’s version, as credited by the trial court, was that on the night of August 31, 1991, after attending church activities, Cadeliña returned to her rented house. She saw Padero sleeping on the ground floor. She went upstairs to sleep alone. At about 11:00 PM, she woke up to find Padero on top of her, holding a knife and threatening to kill her if she shouted. Out of fear, she did not shout. Padero removed her clothes and raped her. He warned her not to report the incident. She only revealed the rape months later when she discovered she was pregnant.
The defense version, presented by Padero himself and several witnesses, was that he and Cadeliña had a consensual sexual relationship that began in March 1991. He testified they had sexual intercourse around fifteen times, with the first instance occurring in August 1991. He claimed the complaint was filed because he ended the relationship in October 1991 and because Cadeliña’s mother wanted financial support for the unborn child, which his mother was willing to provide only after seeing the child’s appearance. Defense witnesses testified to seeing Cadeliña and Padero in intimate situations.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED Henry Padero on the ground of reasonable doubt.
The Court found serious doubts regarding the prosecution’s narrative. It noted that the complainant’s testimony contained improbabilities. She claimed she was raped at knifepoint on a bed on the second floor, yet she did not explain how the accused, who was allegedly sleeping on the ground floor, entered the locked second-floor room without her hearing him. Her testimony about the disposition of the knife after the incident was also unclear and inconsistent. Furthermore, the Court found it contrary to human experience that the complainant, who claimed to have been violently raped and threatened, would continue to live in the same house and even have casual conversations with the accused afterward, as her own testimony suggested.
While the Court condemned the accused’s morally reprehensible conduct in engaging in a sexual relationship with his niece-in-law, it emphasized that a conviction for rape must be based on proof beyond reasonable doubt. The inconsistencies and improbabilities in the complainant’s testimony failed to meet this standard. The constitutional presumption of innocence therefore prevailed.