GR 133003; (April, 2003) (Digest)
G.R. No. 133003 ; April 9, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LAWRENCE MACAPANPAN y DE GUZMAN and AIROLL ACLAN y MENDOZA, accused-appellants.
FACTS
The case stemmed from an Information charging Lawrence Macapanpan and Airoll Aclan with the crime of rape committed against Pauline Pacurib on the evening of February 9, 1996, in Pakil, Laguna. The prosecution alleged that during a blow-out celebration hosted by Pacurib, she was given gin until she felt dizzy and weak. She was then brought to a room where, according to her testimony, Macapanpan and Aclan successively had sexual intercourse with her against her will. She claimed she tried to resist but was overpowered. The defense, however, presented a different version, asserting that the sexual encounter was consensual and that the complaint was filed due to pressure from Pacurib’s mother after the relationship was discovered.
ISSUE
The core issue is whether the guilt of the accused-appellants for the crime of rape was proven beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED both accused-appellants. The Court emphasized that while the testimony of a rape victim is often given full credence, it must still pass the test of credibility and be consistent with human nature and the normal course of things. In this case, the Court found the complainant’s testimony replete with serious inconsistencies and improbabilities that eroded its credibility. For instance, her account of the alleged resistance—such as claiming to have bitten the penis of one appellant—was not mentioned in her initial statements and was deemed a belated and incredible addition. Furthermore, her conduct immediately after the alleged incident, including returning to the drinking session and failing to immediately report the assault, was contrary to the natural behavior of an aggrieved rape victim. The medical findings also did not provide conclusive support for her claim of forced intercourse. The Court held that the prosecution failed to overcome the constitutional presumption of innocence. The evidence did not establish moral certainty of guilt, and the numerous doubts were resolved in favor of the accused. The trial court’s judgment was reversed and set aside.