G.R. No. 190178 ; February 12, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FELIMON PATENTES y ZAMORA, Accused-Appellant.

FACTS

The prosecution alleged that on December 5, 1998, appellant Felimon Patentes forcibly abducted AAA by threatening her with a bolo and a steel pipe on a bus. He brought her to his family home, where he detained her for over a week. During this period, he repeatedly raped her through force, intimidation, and by making her inhale smoke from a substance that rendered her weak and dizzy. AAA escaped on December 13 by feigning agreement to marry him. Upon returning home, she immediately disclosed the rapes to her mother, leading to a medical examination and police report. The medical findings noted a contusion but an intact hymen and no spermatozoa.
The defense presented a version of consensual relations. Appellant claimed AAA voluntarily accompanied him, stayed at his house willingly due to familial discord, and engaged in consensual sex as part of a marriage agreement. Defense witnesses testified to AAA’s apparent freedom of movement within the household and her participation in chores, supporting the claim of a romantic relationship rather than abduction and captivity.

ISSUE

The core issue is whether the prosecution proved the crimes of forcible abduction with rape beyond reasonable doubt, hinging on the credibility of AAA’s testimony against the defense of consensual relationship.

RULING

The Supreme Court acquitted the appellant. The Court emphasized that while the testimony of a rape victim is often given great weight, it must be scrutinized with utmost caution, especially when the conviction rests solely thereon. Here, AAA’s testimony contained significant inconsistencies and was contradicted by the physical evidence and surrounding circumstances. The medical report showing an intact hymen and absence of spermatozoa, despite allegations of repeated rape over days, created reasonable doubt. Furthermore, the alleged captivity in a house full of appellant’s relatives, without any attempt to seek help from them, and her observed free movement undermined the claim of forcible abduction.
The Court found the defense of a consensual romantic relationship leading to a marriage pact more consistent with the evidence. The prosecution failed to overcome the constitutional presumption of innocence. The totality of evidence did not meet the required moral certainty for conviction. Consequently, the Court reversed the lower courts’ decisions and ordered appellant’s immediate release.