G.R. No. L-46521. January 22, 1980.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TIBURCIO RELACION, defendant-appellant.

FACTS

Tiburcio Relacion was convicted of rape by the Court of First Instance of Bohol and sentenced to reclusion perpetua. The prosecution alleged that on June 12, 1975, Relacion, by means of force and intimidation, had sexual intercourse with Anecita Madronero against her will. The prosecution’s evidence included the complainant’s testimony, a medical report indicating minor injuries on her body, her immediate report to her parents and the police, and Relacion’s departure for Bukidnon days after the incident.
The defense, however, presented a contrary version, asserting that the sexual act was voluntary as the accused and the complainant were sweethearts who had engaged in prior consensual relations. The trial court, in convicting Relacion, relied on four circumstances: the complainant’s broken umbrella (indicating a struggle), the medical findings of injuries, her prompt complaint, and the accused’s flight to Bukidnon.

ISSUE

Whether the prosecution’s evidence is sufficient to prove the guilt of the accused for the crime of rape beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Tiburcio Relacion. The Court meticulously deconstructed the trial court’s four bases for conviction, finding them insufficient to establish guilt beyond reasonable doubt. First, the alleged broken umbrella was never presented in evidence, and the complainant’s own testimony revealed she did not use it for defense, making any inference of a violent struggle speculative. Second, the minor injuries documented in the medical report were not conclusively linked to a rape struggle, especially given testimony that the complainant was allegedly boxed on the thigh—an area where no injuries were noted.
Third, while a prompt complaint can corroborate a rape charge, its weight is diminished when the complainant’s overall credibility is questionable. Finally, the evidence did not substantiate “flight” as evidence of guilt. Relacion left for Bukidnon for employment on June 16, 1975, before any criminal complaint was formally filed on June 17, and he worked there with a cousin of the complainant, undermining the inference that he fled to evade arrest. The Court found an equiponderance of evidence between the prosecution’s theory of forcible rape and the defense’s theory of a consensual relationship. Consequently, the prosecution failed to discharge its burden of proving guilt beyond a reasonable doubt, necessitating acquittal.