GR 116738; (March, 1999) (Digest)
G.R. No. 116738 March 22, 1999
PEOPLE OF THE PHILIPPINES, petitioner, vs. RODRIGO DOMOGOY, ALLAN CUIZON and ELMER FRAGA, defendants, RODRIGO DOMOGOY, defendant-appellant.
FACTS
Accused Rodrigo Domogoy, along with Allan Cuizon and Elmer Fraga, was charged with the rape of Angeles Adorable. The prosecution alleged that on September 25, 1992, Domogoy, with the aid of his co-accused who acted as lookouts, forcibly had carnal knowledge of Adorable at the Bislig Municipal High School. The defense moved to quash the information based on a letter allegedly written by Adorable pardoning Domogoy, but the trial court denied the motion. During trial, the parties stipulated that sexual intercourse occurred but contested whether it constituted rape.
The prosecution presented Adorable as its sole witness. She testified that Domogoy, armed with a knife, forced her to the school, where he sexually assaulted her while Cuizon and Fraga watched. The defense presented Domogoy, who claimed the sexual act was consensual, and Fraga, who corroborated this. The trial court convicted Domogoy of rape and sentenced him to reclusion perpetua, while acquitting Cuizon and Fraga for lack of evidence. Domogoy appealed.
ISSUE
Whether the guilt of accused-appellant Rodrigo Domogoy for the crime of rape was proven beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Domogoy. The Court emphasized that in rape cases, the conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The complainant’s testimony must be credible, consistent, and convincing to warrant a conviction.
The Court found the prosecution’s evidence insufficient. The complainant’s testimony contained significant inconsistencies, such as her initial claim of being a virgin contradicted by the medical certificate indicating an old, healed hymenal laceration. Her behavior after the alleged incident—failing to immediately report it and writing a friendly letter to the accused—was deemed contrary to the natural reaction of a victim. The Court also noted the lack of clear, positive identification of the other accused as lookouts during the stipulated facts. Given these doubts, the constitutional presumption of innocence prevailed. The evidence did not meet the required moral certainty to prove force, intimidation, or lack of consent beyond reasonable doubt.