GR 120469; (May, 1999) (Digest)
G.R. No. 120469 May 18, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROTELDO TORION, accused-appellant.
FACTS
Roteldo Torion was convicted of rape by the trial court and sentenced to reclusion perpetua. The complainant, Eufemia Codera, a fourth-degree cousin who had lived with Torion’s family for a year, alleged that in the early morning of May 30, 1992, Torion raped her in the house of his daughter, which she had moved into the previous day. She claimed he threatened her with a balisong, forced himself on her, and ejaculated. She reported the incident to Torion’s wife on the same day and later to the police in June 1992. The prosecution relied solely on her testimony.
The defense presented a different narrative. Torion claimed that on May 29, his wife, Rita, admonished Eufemia for scandalous drinking with male neighbors, leading to an altercation and Eufemia’s move to the daughter’s house. Another serious argument and physical scuffle occurred between Rita and Eufemia in the early morning of May 30, resulting in Rita’s injuries, which were treated by a doctor and reported to the barangay, leading to an amicable settlement. Torion suggested the rape charge was fabricated in retaliation for these quarrels.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Torion. The Court held that while the lone testimony of a rape victim can sustain a conviction, such testimony must be credible, consistent, and in accord with human experience. The Court found Eufemia’s testimony replete with material inconsistencies on crucial details, such as whether the other occupants of the house were asleep or awake during the alleged rape and whether she was asleep or awake when the assault began. These contradictions seriously impaired the probative value and integrity of her testimony.
Furthermore, the Court found the narrative contrary to human experience. It questioned why Torion, who had daily access to Eufemia for a year while she lived in his house, would wait to commit the rape only after she had moved a few meters away. This delay was deemed inconsistent with the behavior of a person driven by unbridled lust. Consequently, the prosecution failed to overcome the constitutional presumption of innocence with proof beyond reasonable doubt. The evidence did not establish guilt with moral certainty, compelling the Court to acquit the accused.