G.R. No. 135049 ; May 28, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARTURO OCOMEN Y ABRASALDO, accused-appellant.

FACTS

Accused-appellant Arturo Ocomen was charged with the rape of his 15-year-old daughter, Kristine Ocomen, allegedly committed in February 1998 in San Manuel, Pangasinan. The prosecution presented Kristine’s sworn statement detailing the alleged rape, wherein she stated her father tied her hands, removed her clothing, and had carnal knowledge of her. Medical examination confirmed healed hymenal lacerations consistent with sexual intercourse. However, during the trial, Kristine executed an affidavit of desistance, expressing forgiveness and a desire to drop the charges. She subsequently became unavailable to testify despite court orders for her appearance.
When finally located and presented in court, Kristine gave testimony that was materially inconsistent with her prior sworn statement. She recanted her detailed account of the rape, testifying instead that her father merely slapped her and that he did nothing more after going downstairs. The prosecution’s case thus rested on her prior extrajudicial affidavit, as her in-court testimony failed to substantiate the allegations of sexual assault.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED accused-appellant Arturo Ocomen. The legal logic hinges on the fundamental principle that a conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The core of the prosecution’s case was the testimony of the private complainant, Kristine. Her in-court testimony completely contradicted and failed to corroborate her earlier sworn statement alleging rape. She explicitly denied the sexual assault in her judicial testimony.
The Court emphasized that while an affidavit of desistance does not automatically result in acquittal, the judicial confession in open court holds greater weight than any prior extrajudicial statement. When a complainant repudiates her prior accusations on the witness stand, the basis for conviction collapses. The medical findings, while indicating prior sexual activity, could not by themselves prove that the accused was the perpetrator, especially in light of the victim’s recantation. Consequently, the prosecution failed to discharge its burden of proving all elements of the crime beyond reasonable doubt. The constitutional presumption of innocence therefore prevails.