PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOSELITO BAGUIO y SANTOS, Accused-Appellant. G.R. No. 250875, June 28, 2021.

FACTS:
Accused-appellant Joselito Baguio y Santos was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution alleged that on December 25, 2015, in Quezon City, the accused, by means of force, threat, and intimidation, had carnal knowledge of AAA, a 14-year-old minor. The defense interposed the defense of denial and alibi, claiming he was elsewhere during the incident. The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to *reclusion perpetua*. The Court of Appeals (CA) affirmed the RTC decision in toto. The case was elevated to the Supreme Court via an appeal.

ISSUE

Whether the guilt of the accused-appellant for the crime of Rape has been proven beyond reasonable doubt.

RULING

NO, the guilt of the accused-appellant was not proven beyond reasonable doubt. The Supreme Court ACQUITTED Joselito Baguio y Santos.

The Court emphasized that in rape cases, the conviction of the accused must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The credibility of the victim’s testimony is paramount. However, after a meticulous review, the Court found the testimony of the private complainant (AAA) to be replete with inconsistencies and contradictions on material points regarding the alleged rape incident. These inconsistencies pertained to the sequence of events, the use of force, and her opportunity to escape or seek help, which cast reasonable doubt on the veracity of her account. The prosecution failed to establish the essential element of force, threat, or intimidation with the required moral certainty. When the evidence for the prosecution fails to meet the test of moral certainty and does not overcome the constitutional presumption of innocence, the accused is entitled to an acquittal. Accordingly, the Court reversed the decisions of the lower courts and ordered the immediate release of the accused-appellant unless he is being lawfully held for another cause.