GR 126121; (November, 1998) (Digest)
G.R. No. 126121 November 24, 1998
People of the Philippines, plaintiff-appellee, vs. Joel Lamarroza, accused-appellant.
FACTS
Accused-appellant Joel Lamarroza was charged with the rape of Elena Andaya, an 18-year-old, alleged to have occurred in February 1993 in Tagudin, Ilocos Sur. Both lived in the same barangay with houses approximately 60 meters apart. In August 1993, Elena’s mother noticed her daughter’s unusual size and brought her to a doctor, who found Elena to be six months pregnant. Elena’s mother then complained to barangay officials and the mayor, pointing to Joel as the rapist, and subsequently filed a formal charge. In her sworn statement and court testimony, Elena claimed Joel had sexual intercourse with her against her will in February 1993, resulting in her pregnancy. However, on cross-examination, Elena admitted she had prior sexual intercourse with another man named Fortun, though she claimed Fortun did not impregnate her and that the child resembled Joel. Joel denied the accusation, testifying he was a student staying in a boarding house during school days and only went home on weekends. He asserted Fortun was the father of Elena’s child. The trial court convicted Joel based on Elena’s testimony.
ISSUE
Whether the prosecution proved beyond reasonable doubt that Joel Lamarroza committed rape against Elena Andaya.
RULING
No. The Supreme Court reversed the trial court’s decision and acquitted Joel Lamarroza. The Court applied the basic principles in rape cases: an accusation is easy to make but hard to disprove; the complainant’s testimony must be scrutinized with great caution; and the prosecution’s evidence must stand on its own merit. Elena’s testimony failed to establish rape. Her description of the act, including that she “enjoyed” it and her laughter when answering, was inconsistent with a lack of voluntariness required in rape by force. Her conduct after the alleged incident—remaining friendly with Joel and going out with him—was unnatural for a rape victim. The prosecution’s attempt to establish Elena as a mental retardate was unsupported, as the medical certificate presented was hearsay, lacking testimony from the examining psychiatrist. The Court found that Elena and her family, scandalized by her pregnancy, wrongly attributed it to rape, confusing impregnation with the crime. The prosecution’s evidence was insufficient to prove guilt beyond reasonable doubt.