G.R. No. 133997 . May 17, 2001.
People of the Philippines, plaintiff-appellee, vs. Felixberto Aballe, accused-appellant.

FACTS

The case involves the rape accusation by Era Sinangote against Felixberto Aballe (“Noy Berting”), her employer. Era testified that on June 2, 1988, around 5:00 PM, while she was preparing supper, Aballe suddenly embraced her from behind, fondled her breasts, declared his love, and carried her. She hit him with a ladle. He dropped her on the kitchen floor, covered her mouth, positioned himself on top of her, ripped her panty, and inserted his penis into her vagina, causing pain until he ejaculated. He then threatened her if she revealed the incident. After he left, she went to the maid’s quarters. Later, she told her cousin Vilma they should leave due to the threats, and they left the next morning. Era later discovered she was pregnant. She initially confided in her sister Lolita Andrin. The family sought financial assistance from Aballe for the delivery, but he refused and instead filed a robbery case against Lorie (Era’s sister) and Marte Andrin (Lolita’s husband). This prompted the family to file a rape complaint. Era gave birth to a baby girl on February 21, 1989. Lolita corroborated Era’s account, testifying that Aballe admitted the rape and offered to pay for an abortion, which Era refused. Aballe, testifying in his defense, admitted to a consensual sexual relationship with Era, claiming they had multiple sexual encounters beginning in April 1988, including at a motel, and that his wife left him due to the affair. He denied raping her.

ISSUE

The central issue is the credibility of the complaining witness, Era Sinangote, and whether her testimony is sufficient to prove the guilt of the accused-appellant, Felixberto Aballe, for rape beyond reasonable doubt.

RULING

The Supreme Court acquitted accused-appellant Felixberto Aballe. The Court found the testimony of the complaining witness, Era Sinangote, not credible. Her narrative was deemed implausible and inconsistent. The Court noted several improbabilities: the alleged rape occurred in a kitchen where other household members could have been present, yet no one heard any struggle; her actions after the incident (e.g., casually opening the door and asking about supper) were unnatural for a rape victim; and there was a significant delay in reporting the rape, which she only disclosed after pregnancy was confirmed and after a failed attempt to secure financial assistance from the accused. The Court also found material inconsistencies in her testimony and that of her witnesses regarding key events, such as the reporting of the incident and Aballe’s alleged marriage proposal. In contrast, the accused’s claim of a consensual affair was supported by details of their clandestine meetings and the reaction of his wife. The Court emphasized that while contradictions do not automatically acquit an accused, the prosecution must prove guilt beyond reasonable doubt. In this case, the prosecution failed to meet this burden due to the inherent improbabilities and inconsistencies in the victim’s story, which cast reasonable doubt on the accused’s guilt.