GR 240662; (September, 2020) (Digest)
G.R. No. 240662 , September 16, 2020
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. RAYMUNDO RAPIZ Y CORREA, ACCUSED-APPELLANT.
FACTS
The accused-appellant, Raymundo Rapiz y Correa, was charged with the rape of AAA, his alleged niece, on April 2, 2015, in Las Piñas City. The prosecution presented AAA’s testimony that appellant, armed with a deadly weapon, forced her to have sexual intercourse. She further testified to subsequent acts of sexual abuse on April 3 and 4. The medico-legal report confirmed recent blunt penetrating trauma to her hymen. The defense, however, presented a different narrative. Appellant claimed the accusation was fabricated by AAA’s mother, BBB, after he refused to lend her money. He asserted that BBB and AAA had a tumultuous relationship and that he had moved out of their shared compound due to shame over their behavior. The trial court convicted appellant of simple rape, a decision affirmed by the Court of Appeals with modifications to the damages awarded.
ISSUE
Whether the guilt of the accused-appellant for the crime of rape has been proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted appellant on the ground of reasonable doubt. The Court meticulously examined the evidence and found the prosecution’s case fatally flawed. Critical inconsistencies pervaded AAA’s testimony. She vacillated on whether a weapon was used, gave contradictory accounts of the number of rape incidents, and provided irreconcilable details about the time and location of the alleged assaults. The medico-legal findings, while indicating sexual activity, were not conclusive of rape and did not corroborate the specific incident alleged in the Information. The Court emphasized that the constitutional presumption of innocence must prevail when the evidence for the prosecution fails to meet the stringent standard of proof beyond reasonable doubt. The weakness of the defense, such as appellant’s denial and motive of revenge, does not relieve the prosecution of its burden. Where the prosecution’s evidence is weak and creates reasonable doubt, acquittal is mandatory.