G.R. No. 134309 ; November 17, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO MARIANO alias ATO, accused-appellant.

FACTS

Roberto Mariano was convicted of rape by the Regional Trial Court of Pasig City and sentenced to death for allegedly raping his four-year-old neighbor, Khristine Custan, on February 17, 1995. The prosecution’s narrative, primarily from Khristine and her mother Evelyn, stated that Khristine was playing in Mariano’s room when he sent his children to a store, leaving them alone. He then allegedly carried her to bed, removed their clothes, and inserted his penis into her vagina. Evelyn later noticed Khristine’s panty was inside out and, upon questioning, learned of the alleged assault. A medical examination conducted on the same day concluded Khristine was in a “virgin state physically” with no external signs of violence and negative findings for spermatozoa.
Mariano presented a different account. He testified that Khristine was playing with his children that afternoon, and he gave them money to buy snacks so he could rest. He denied any molestation, suggesting the accusation arose from a confrontation initiated by Evelyn, who allegedly threatened him due to a prior dispute. He argued that the family’s immediate move after the incident and the long delay before his arrest over a year later cast doubt on the prosecution’s story.

ISSUE

The core issue is whether the guilt of Roberto Mariano for the crime of rape was proven beyond a reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Roberto Mariano. The Court emphasized that in rape cases, the accused’s conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The prosecution failed to meet the burden of proof beyond reasonable doubt. Critical inconsistencies undermined the credibility of the narrative. The medico-legal report directly contradicted the claim of recent sexual intercourse, finding Khristine physically intact with no evidence of sperm or trauma. Furthermore, the testimony of the child victim contained material inconsistencies, such as conflicting accounts of who told her to dress and leave. The Court also found the behavior of the complainant’s family unusual; despite the alleged brutal rape of a young child, they did not immediately seek medical aid or report to the nearest police station, and they waited over a year before acting on a warrant despite knowing Mariano’s whereabouts. These circumstances, combined with the lack of corroborative physical evidence, created reasonable doubt. The constitutional presumption of innocence prevailed, necessitating acquittal.