G.R. No. 130651 ; November 22, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANTE DESAMPARADO y DIOLA, accused-appellant.

FACTS

The prosecution alleged that on February 24, 1997, in Bacolod City, accused-appellant Dante Desamparado, armed with a knife, forcibly had carnal knowledge of the 13-year-old complainant, Joan Patatag, at a seashore. The complainant testified she was seized, threatened with death, and raped, causing her pain and bleeding. She was later found by her aunt and others, crying and trembling. A medical examination revealed fresh hymenal lacerations and other injuries consistent with recent sexual intercourse. The police recovered a piece of cloth with bloodstains from the scene.
The defense interposed alibi. Accused-appellant claimed he was at his cousin’s house obtaining food, then returned home for supper and slept, only to be arrested later. Defense witnesses corroborated his whereabouts. Furthermore, two defense witnesses testified that the complainant initially identified a certain “Obet” as her rapist when first found.

ISSUE

Whether the guilt of accused-appellant Dante Desamparado for the crime of rape was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted accused-appellant on the ground of reasonable doubt. 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. While the medical evidence conclusively established that the complainant had recent sexual intercourse, the evidence identifying accused-appellant as the perpetrator was fraught with inconsistencies and failed to meet the required moral certainty.
The Court found the complainant’s identification of accused-appellant unreliable. Her testimony contained material inconsistencies, particularly regarding her initial reaction upon being found by her rescuers. She testified she ran away from them out of fear, which the Court found incongruent with the behavior of a victim who had just been assaulted by a stranger. This cast doubt on her narrative. Crucially, defense witnesses testified that the complainant initially named another person, “Obet,” as her assailant. This seriously undermined her subsequent identification of accused-appellant. The purported bloodstained cloth was also of no evidentiary value without laboratory testing to match the blood to accused-appellant. The defense of alibi, while generally weak, assumed significance in light of the prosecution’s failure to positively and convincingly prove accused-appellant’s identity as the rapist. Consequently, the element of the offender’s identity was not established beyond reasonable doubt, warranting acquittal.