GR 131828; (December, 1999) (Digest)
G.R. No. 131828 December 15, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE CABALIDA, accused-appellant.
FACTS
Accused-appellant Felipe Cabalida was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The prosecution alleged that on May 29, 1995, Cabalida, a 47-year-old seaweeds farmer and neighbor, raped his 15-year-old grandniece-by-affinity, Harhada Lackua, at gunpoint in his house. Harhada testified she was watching TV with Cabalida’s daughter, Helen, fell asleep, and upon waking found herself alone. Cabalida allegedly grabbed her, covered her with a blanket, dragged her to a bedroom, pointed a gun at her, and forcibly had intercourse. She reported the incident only months later, after discovering her pregnancy.
The defense presented an alibi. Cabalida denied the rape, testifying he was at sea early that morning and returned only at 6:00 p.m. His daughter, Helen, corroborated this, stating she did not recall being with Harhada that afternoon. The defense also highlighted that Harhada’s stepfather, Alejandro Lebrado, was named as the father on the child’s birth certificate and suggested the accusation was fabricated. Cabalida voluntarily returned from Palawan to face the charges.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED accused-appellant Felipe Cabalida. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution to establish guilt beyond reasonable doubt, and the accused enjoys the presumption of innocence. The trial court erred in convicting the accused primarily based on the complainant’s supposed “boldness” in filing the charge, without critically examining the inconsistencies and improbabilities in her testimony. The Court found the evidence insufficient to overcome the constitutional presumption of innocence. Notably, the defense presented a credible alibi supported by witness testimony, and the birth certificate naming another man as the father of the child created reasonable doubt regarding paternity and the narrative of the crime. The accused’s voluntary return to face the charges was also considered indicative of innocence. Consequently, the prosecution failed to meet the required standard of proof.