G.R. No. 130969 February 29, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO SAN JUAN, accused-appellant.

FACTS

The prosecution alleged that on May 4, 1994, accused-appellant Roberto San Juan raped sixteen-year-old Rowena Morla. Rowena testified that she was asleep in her room when San Juan, a neighbor, awakened her by kissing her lips while holding a bladed weapon to her neck. He threatened to kill her if she made noise. When her father called out from the adjacent room, she answered “Wala po” out of fear. San Juan then forced her to walk to an open field, where he made her lie down, removed her clothing, and had carnal knowledge of her twice, all while keeping the knife pointed at her neck. She reported the incident to her parents, underwent a medical examination which confirmed recent hymenal lacerations, and executed a sworn statement.
The defense presented a contrary version. San Juan claimed he and Rowena were sweethearts since January 1994, meeting secretly as her parents disapproved of him. He went to her house that evening upon her invitation. After her father was momentarily alerted, they voluntarily went behind a chapel where they had consensual sexual intercourse. Rowena suggested eloping and returned home to fetch her necklace and clothes, but he overheard her mother scolding her. He was later arrested. His sister corroborated their romantic relationship.

ISSUE

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

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Roberto San Juan. The Court found that the prosecution failed to prove his guilt beyond reasonable doubt. The credibility of the complainant’s testimony was critically examined. The Court noted inherent improbabilities in her narrative, such as her failure to resist or cry for help when initially accosted inside her home with her parents nearby, and her claim of being led at knifepoint in a quiet neighborhood without any outcry. These acts were deemed contrary to human instinct for self-preservation.
Furthermore, the Court found the defense of a romantic relationship plausible, supported by the testimony of the accused’s sister. It considered the possibility that the charge was fabricated to conceal an indiscretion and avoid familial dishonor in a small rural community. The medical findings, while indicating recent sexual activity, were not conclusive of rape and were consistent with consensual intercourse. The constitutional presumption of innocence must prevail when the evidence does not establish moral certainty of guilt. The prosecution’s evidence, fraught with doubt, was insufficient to overcome this presumption.