GR 43789; (July, 1981) (Digest)
G.R. No. L-43789 July 15, 1981
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARISTON FRANCISCO, defendant-appellant.
FACTS
The case involves the automatic review of the death penalty imposed on appellant Ariston Francisco for the crime of rape. The Information alleged that on January 28, 1972, in Oriental Mindoro, appellant, conspiring with Ruby Poras (who remained at large initially), waylaid 13-year-old Mercedita Manito and her sister. Using force and intimidation, and armed with a knife, they dragged Mercedita to a secluded area where appellant and Poras successively had sexual intercourse with her. After appellant’s escape and subsequent recapture, and the provisional dismissal of the case against Poras, trial proceeded solely against appellant. The prosecution relied on Mercedita’s testimony detailing the assault, her resistance, and the pain she endured. The defense presented only appellant, who denied the accusation.
ISSUE
The core issue is whether the prosecution proved appellant’s guilt for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED appellant Ariston Francisco. The conviction was reversed due to the prosecution’s failure to prove his guilt beyond reasonable doubt. The Court emphasized that in rape cases, the complainant’s testimony must be scrutinized with extreme caution and must be credible, natural, convincing, and consistent with human nature and the normal course of things. The Court found Mercedita’s account replete with incredible details that eroded its reliability. Her claim that she fainted after the assault, yet awoke to find her assailants gone and walked home alone at 4 a.m., was deemed unnatural. More critically, her immediate conduct was inconsistent with that of a victim who had just endured a violent crime. She did not report the incident to her father or siblings upon arriving home, even though her younger sister (who had fled) was present. She washed her blood-stained garment the next morning to conceal the event. This delay of over two months in reporting to authorities, coupled with the absence of any physical examination evidence and the provisional dismissal of the case against her other alleged assailant for a monetary consideration, created profound doubt. The totality of these circumstances failed to meet the requisite moral certainty for a conviction, especially one carrying the supreme penalty of death.