GR 38463; (December, 1978) (Digest)
G.R. No. L-38463 December 29, 1978
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN LACUNA y FRANCISCO, accused-appellant.
FACTS
The prosecution’s case rested primarily on the testimony of Emily Beltran, a married but estranged student. She testified that on March 13, 1970, her classmate and rejected suitor, appellant Benjamin Lacuna, abducted her at gunpoint from her school in Mandaluyong. She was taken to various locations in Sta. Ana, Manila, where she was detained. Beltran claimed that over several days, Lacuna, through force and threats against her children, succeeded in having sexual intercourse with her multiple times. She was eventually released after being forced to call her sister-in-law, Lourdes Beltran, who fetched her. Medical examinations confirmed recent sexual activity. The defense presented a different narrative, alleging a consensual romantic relationship and elopement.
ISSUE
The core issue was whether the prosecution proved the guilt of the appellant for the complex crime of forcible abduction with rape beyond a reasonable doubt.
RULING
The Supreme Court ACQUITTED the appellant. The Court meticulously scrutinized the complainant’s testimony, noting inherent improbabilities that eroded its credibility. It found the claim of abduction at a busy school gate without intervention dubious. The Court also highlighted the complainant’s own admission of minimal physical resistance during the alleged assaults, coupled with her failure to seize opportunities to escape during unguarded moments or seek help from others she encountered. These circumstances were inconsistent with the conduct of someone forcibly deprived of liberty. The Court emphasized that in crimes of this nature, which typically lack eyewitnesses, the complainant’s testimony must be credible and consistent with human experience. The prosecution’s corroborative evidence, particularly the hearsay statement of Joseph Pascual (Exhibit “D”) who was not presented for cross-examination, was inadmissible. The evidence for the defense, suggesting a consensual affair, cast sufficient doubt on the prosecution’s version. Consequently, the evidence failed to meet the required standard of proof beyond reasonable doubt, warranting acquittal.