G.R. No. 124342 December 8, 1999
People of the Philippines vs. Edwin Ladrillo
FACTS
The prosecution alleged that accused-appellant Edwin Ladrillo raped his eight-year-old cousin, Jane Vasquez, four times in one afternoon at his house in Abanico, Puerto Princesa City. Jane testified that Ladrillo, after asking her to pick lice from his head, made her lie down, removed her panty, and inserted his penis into her vagina, covering her mouth. She claimed this act was repeated after each time his penis softened. The incident was reported in 1994 after Jane exhibited physical discomfort. A medico-legal certificate indicated a “non-intact hymen,” which the doctor testified could be congenital or due to trauma. The Information stated the crime occurred “on or about the year 1992.”
The defense presented alibi and denial. Ladrillo claimed he was residing in Liberty, Puerto Princesa City, in 1992 and only moved to Abanico in 1993, not knowing the complainant then. Defense witnesses corroborated his residence timeline. His father testified that the complaint was fabricated by Jane’s mother, Salvacion, due to a family quarrel. The trial court convicted Ladrillo of rape, sentencing him to reclusion perpetua.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Edwin Ladrillo. The Court emphasized that the prosecution must rely on the strength of its own evidence and not on the weakness of the defense. Critical inconsistencies undermined the prosecution’s case: the Information alleged the rape occurred “on or about the year 1992,” but the complainant could not specify the date, and evidence suggested the accused did not reside at the crime scene until 1993. The medico-legal finding of a “non-intact hymen” was inconclusive, as it could be congenital. The testimony of the young victim, while given weight, was insufficient to establish guilt beyond reasonable doubt when the specific time of the offense remained unproven and the accused’s presence was credibly contested. The constitutional presumption of innocence prevailed, and any reasonable doubt mandated acquittal.