GR 114291; (May, 1997) (Digest)
G.R. No. 114291 May 14, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JACINTO SALAZAR, @ “JAKE”, accused-appellant.
FACTS
The prosecution’s evidence established that on February 23, 1993, 16-year-old student Jennette David was invited to the house of the accused, Jacinto Salazar, a security guard at her school. Once there, Salazar allegedly sent his children away, poked a knife at her neck, dragged her to a bedroom, and raped her. He then threatened to kill her and her family if she reported the incident. Jennette did not disclose the rape until June 1993, when she became ill and desolate, after which she was medically examined and a complaint was filed. The defense presented a contrasting narrative, asserting that Jennette and Salazar had an existing intimate relationship. This was supported by a love letter and a composition written by Jennette expressing deep affection for Salazar, as well as testimony from defense witnesses that Jennette frequently visited him and gave him gifts like fruits and a watch.
ISSUE
Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED the accused. The Court applied the settled principles in reviewing rape cases: accusations are easy to make but hard to disprove; the complainant’s testimony must be scrutinized with great caution; and the prosecution’s case must stand on its own merits. The Court found the complainant’s testimony fraught with inherent improbabilities and material inconsistencies that eroded its credibility. Crucially, evidence of a pre-existing intimate relationship, including a handwritten love letter from the complainant to the appellant admitting her love and promising constancy, severely undermined the claim of a forcible sexual assault. The Court reasoned that it was improbable for a ravished victim to subsequently give her alleged violator gifts and express profound affection. Furthermore, the judge who rendered the conviction did not personally hear the complainant’s testimony and observe her demeanor, thus the Court was not bound by the trial court’s credibility assessment. Since the prosecution’s evidence failed to meet the exacting standard of proof beyond reasonable doubt, the constitutional presumption of innocence prevailed. The award of damages was consequently set aside.