G.R. No. 117451 September 29, 1997
PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, vs. ANTON BURGOS, JOHN EVANGELISTA, ROOSEVELT ROSETE and FRANCISCO CABAÑGAN, accused. ANTON BURGOS, accused-appellant.

FACTS

Accused-appellant Anton Burgos, a tricycle driver, was charged with forcible abduction with rape. The prosecution’s case rested solely on the testimony of the victim, Lilibeth Abad. She testified that on October 21, 1992, after boarding Burgos’s tricycle to go home, he instead drove her to an abandoned house in another barangay. His three male passengers alighted en route. At the house, Burgos allegedly threatened her with a knife and raped her three times against her will. She reported the incident the next day. A medical examination revealed no fresh hymenal lacerations but noted tenderness and an abrasion. The trial court convicted Burgos of the complex crime and sentenced him to reclusion perpetua, acquitting his co-accused for insufficiency of evidence.
Burgos presented a contrary version, claiming the encounter was consensual. He testified that he and Abad had an agreement to go to San Agustin, visited his uncle, and mutually decided to spend the night in another relative’s house. He denied using force or a knife. The defense highlighted inconsistencies in Abad’s testimonies, particularly the number of times sexual intercourse occurred and, crucially, her statement during cross-examination that she experienced a “sensation of enjoyment” during all three acts.

ISSUE

Whether the guilt of the accused-appellant for the crime of forcible abduction with rape was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Anton Burgos on the ground of reasonable doubt. The Court emphasized that in rape cases, the complainant’s testimony must be scrutinized with extreme caution and must be credible, natural, convincing, and consistent with human nature and the normal course of things. While the Court acknowledged that inconsistencies on minor details do not necessarily impair a witness’s credibility, it found that the inconsistencies in Abad’s testimony pertained to material points—the frequency of the sexual act and, most significantly, her admission of experiencing a “sensation of enjoyment.”
The Court ruled that this admission was fatal to the prosecution’s case. Citing the doctrine in People vs. Jervoso, the Court held that it is contrary to human nature and experience for a victim of a violent rape to derive enjoyment from the act. Such a sensation is inconsistent with the presence of force, intimidation, or lack of consent, which are essential elements of rape. Instead, it suggests willing participation. This, coupled with the medical findings which did not conclusively prove forcible intercourse (noting no fresh lacerations and only slight tenderness), created reasonable doubt as to whether the sexual acts were committed against Abad’s will. The prosecution thus failed to meet the required quantum of proof beyond reasonable doubt, necessitating acquittal.