GR 191258; (July, 2015) (Digest)
G.R. No. 191258; July 8, 2015.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VINCENT GARRIDO y ELORDE, Accused-Appellant.
FACTS
Accused-appellant Vincent Garrido y Elorde was charged with rape under Article 266-A in relation to Article 266-B of the Revised Penal Code. The prosecution’s version, as narrated by the victim AAA, stated that on the evening of October 20, 2004, she was invited to a supposed birthday party which turned into a drinking session. After becoming drunk, Garrido offered to take her home but instead brought her, along with BBB and Vernel, to his house. Inside a bedroom, Garrido turned off the lights, forcibly kissed her, removed her clothes, and had carnal knowledge of her against her will multiple times. AAA testified she tried to resist but was weak and exhausted. The medico-legal examination revealed ecchymosis on her breast and deep healed lacerations on her hymen. The defense, however, claimed the sexual intercourse was consensual. Garrido testified that AAA initiated intimacy, and their version was corroborated by witnesses Vernel, Vivence, and Walita Garrido, who stated AAA did not appear drunk and acted normally. The Regional Trial Court found Garrido guilty of rape and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals with a modification on civil indemnity.
ISSUE
Whether the prosecution proved beyond reasonable doubt that accused-appellant Vincent Garrido y Elorde is guilty of the crime of rape.
RULING
The Supreme Court REVERSED the decision of the Court of Appeals and ACQUITTED the accused-appellant based on reasonable doubt. The Court held that the prosecution failed to prove the elements of rape beyond reasonable doubt. While the lone testimony of a credible rape victim can sustain a conviction, such testimony must be scrutinized with extreme caution. The Court found nagging doubts regarding the credibility of AAA’s testimony, noting vacillating statements on whether she refused to be in the room and on the nature of the sexual intercourse. The inconsistencies and the lack of clear, convincing evidence of force, threat, or intimidation created reasonable doubt as to Garrido’s guilt. The evidence for the prosecution must stand on its own merits and cannot draw strength from the weakness of the defense. Consequently, Garrido was acquitted and ordered released unless detained for another lawful cause.