G.R. No. 134292 ; August 16, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCO MORALES, accused-appellant.

FACTS

The case is an appeal from the decision of the Regional Trial Court, Laguna, Branch 35, Calamba, finding accused Franco Morales guilty beyond reasonable doubt of rape and sentencing him to reclusion perpetua and to indemnify the complainant Jennifer Combo. An information was filed charging the accused with rape committed on or about September 6, 1995, in Calamba, Laguna, alleging that he, armed with a kitchen knife and by means of force and intimidation, had carnal knowledge with the 14-year-old Jennifer Combo against her will.
At trial, the prosecution’s version was that on September 6, 1995, at about 7:30 PM, after coming from school, Jennifer rode a tricycle driven by the accused. After the other passengers alighted, the accused brought her to a nipa hut instead of her home. Inside, he poked a knife at her side, led her to a bedroom, and despite her resistance of kicking and pushing for about twenty-five minutes, succeeded in having sexual intercourse with her. She did not shout during the struggle. After the incident, she went home, where her uncle, Gil Manglapuz, met her. She appeared pale but did not immediately report the rape. On October 14, 1995, the accused went to Jennifer’s house, and Gil instructed Jennifer not to talk to him. Four days later, on October 18, 1995, after Gil inquired why she was not jovial, Jennifer narrated the rape. They reported it to the authorities, and she was medically examined.
The defense of accused Franco Morales was a denial. He admitted Jennifer was his passenger that night but claimed she was crying and refused to go home, alleging her uncle maltreated her. He pitied her, brought her to his family’s canteen to seek a job for her, and then, with his parents, took her home. He denied raping her and denied going to her house on October 14, 1995.

ISSUE

The sole issue is whether or not the trial court erred in giving full credence to the testimonies of the prosecution witnesses and thus convicting the accused of the offense charged.

RULING

The Supreme Court ruled that the trial court erred in convicting the accused-appellant. The Court found that the prosecution’s evidence failed to prove guilt beyond reasonable doubt. The testimony of the complainant was scrutinized with great caution and found to be lacking in credibility due to several factors: (1) Her resistance was deemed unnatural—she fought for twenty-five minutes but never shouted for help until the act, and the knife was within reach on the bed yet she did not attempt to use it; (2) The medico-legal report showed no signs of abrasions, contusions, or injuries on her body; (3) There were inconsistencies between her testimony and that of her uncle Gil regarding her arrival home and her interaction with the accused on October 14, 1995; (4) Jennifer initially stated she was “forced by [her] uncle to file this case,” which cast doubt on the complaint’s initiation; and (5) The delay of over a month in reporting the alleged rape, coupled with the uncle’s failure to tell his wife immediately, further undermined the prosecution’s case. Guided by the principle that the evidence for the prosecution must stand on its own merit and cannot draw strength from the weakness of the defense, the Court reversed the conviction. The accused-appellant was acquitted on reasonable doubt.