G.R. No. 181744; October 2, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. ROY BACUS, Appellant.

FACTS

The prosecution alleged that on February 3, 1999, appellant Roy Bacus, a childhood friend, accompanied the 17-year-old victim AAA on her way home. Upon reaching a makeshift hut, appellant suddenly grabbed her, covered her mouth, and at knifepoint forced her to lie under a parked cargo truck where he had sexual intercourse with her against her will. The following day, AAA reported the incident and was medically examined. The medico-legal officer found healed and incomplete healing lacerations on her hymen. Appellant was convicted of rape by the Regional Trial Court and the Court of Appeals, which affirmed the judgment with modifications to the damages awarded.
Appellant admitted to having sexual intercourse with AAA but claimed it was consensual and occurred on February 2, 1999, as they were allegedly sweethearts. He denied using force or intimidation. He challenged the credibility of AAA’s testimony, arguing the physical improbability of the rape occurring under the truck as described and pointing to the medico-legal findings which indicated the sexual intercourse likely occurred more than 24 hours before the examination, aligning with his claim of intercourse on February 2.

ISSUE

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

RULING

The Supreme Court reversed the Court of Appeals and acquitted appellant Roy Bacus on the ground of reasonable doubt. The Court emphasized that in rape cases, where the conviction often hinges on the complainant’s testimony, such testimony must be scrutinized with extreme caution and must be credible, consistent, and convincing. The Court found that the prosecution failed to meet the required quantum of proof.
Key to the acquittal was the medico-legal evidence. The examining physician testified that the lacerations found on AAA were already healing and that there was no fresh bleeding, which would have been expected if the intercourse had occurred within 24 hours of the examination conducted on February 4, 1999. This medical opinion corroborated appellant’s claim that the last consensual intercourse happened on February 2, 1999, not on February 3 as alleged in the information. This created reasonable doubt as to the date of the alleged forcible intercourse. Furthermore, the Court found the surrounding circumstances, including the claimed venue under a truck, cast doubt on the physical feasibility of the rape as narrated. Consequently, the prosecution’s evidence did not establish appellant’s guilt with moral certainty, warranting acquittal.