GR 141280; (June, 2003) (Digest)
G.R. Nos. 141280-81; June 16, 2003
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. RICKY SODSOD Y LOSITO AND DONDON BERNABE Y BERCASIO, Accused-Appellants.
FACTS
The appellants, Ricky Sodsod and Dondon Bernabe, were convicted by the Regional Trial Court of Legazpi City of two counts of forcible abduction with rape and sentenced to reclusion perpetua. The prosecution alleged that on January 3, 1997, the appellants forcibly abducted the complainant, Lilibeth Boridor, by forcing her onto a motorcycle. They took her to a park, made her drink beer, and later brought her to a grassy area along Tahao Road. There, the appellants allegedly took turns having carnal knowledge of her against her will. The defense presented a different version, claiming the complainant voluntarily joined them, consented to drinking, and engaged in consensual sexual acts. They asserted the encounter was a romantic tryst that turned sour when discovered by the complainant’s father.
ISSUE
Whether the guilt of the appellants for the crimes of forcible abduction with rape was proven beyond reasonable doubt.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED the appellants. The Court emphasized that in rape cases, the prosecution must rely on the strength of its own evidence and prove the accused’s guilt beyond reasonable doubt. The Court found the complainant’s testimony replete with inconsistencies and improbable assertions that eroded her credibility. Notably, she claimed to have been forcibly abducted in a busy area without any bystander intervention, and she was unable to explain why she did not immediately escape when opportunities arose, such as at the store where beer was purchased. The medical findings were inconclusive, showing no fresh lacerations, which was inconsistent with a claim of a violent assault by two men. Furthermore, her conduct after the alleged incident—such as being returned to the exact point of abduction and not immediately reporting to authorities—was deemed contrary to human nature and the natural behavioral response of an aggrieved victim. The totality of these circumstances created reasonable doubt as to the occurrence of forcible abduction and the lack of consent. The evidence failed to meet the requisite moral certainty for a criminal conviction.