GR 47469; (December, 1978) (Digest)
G.R. No. L-47469 December 29, 1978
DOMINGO M. LOPEZ, petitioner, vs. PEOPLE OF THE PHILIPPINES and HON. COURT OF APPEALS, respondents.
FACTS
Petitioner Domingo Lopez was convicted of attempted rape by the Court of Appeals. The prosecution’s case rested primarily on the testimony of complainant Yolanda Perez. She testified that on June 3, 1972, she and Lopez, who were former sweethearts, met by chance. Lopez accompanied her in a taxi, but instead of proceeding to her intended destination, they went to a motel in Pasig. There, Lopez allegedly poked a gun at her, forced her onto a bed, removed her underwear, and attempted to have carnal knowledge. Perez claimed she resisted fiercely, pressing her thighs together, and felt a warm, wet sensation on her private part. Lopez allegedly declared she was no longer a virgin and must marry him. They later proceeded to the house of Lopez’s brother-in-law, Atty. Narag, where Perez eventually revealed she had been forced. She was later brought to the Malolos police station.
The defense highlighted significant inconsistencies in Perez’s account. Crucially, the medical certificate issued after the alleged incident only noted hematomas on her legs and thighs and complaints of arm pain, with no findings indicative of sexual assault or recent loss of virginity. Furthermore, the police blotter entry, based on Perez’s initial statement, made no mention of a rape attempt in Pasig. It merely recorded an allegation of abduction from Paombong and that Lopez left her in Caloocan City—a narrative directly contradicted by her own trial testimony about the subsequent events at the Narag residence and her trip to Malolos.
ISSUE
Whether the guilt of the petitioner for the crime of attempted rape was proven beyond a reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted Domingo Lopez. The legal logic centered on the fundamental principle that the prosecution must prove guilt beyond reasonable doubt, and the evidence failed to meet this standard. The Court found the testimony of the complainant inherently incredible and replete with material inconsistencies that eroded its reliability.
The most damaging inconsistency was between her trial testimony detailing a violent attempted rape in a Pasig motel and her initial police blotter statement, which only mentioned abduction and being left in Caloocan. This omission of the core alleged crime at the first reasonable opportunity to report it cast serious doubt on its veracity. Furthermore, her medical examination results were utterly incompatible with her graphic account of a strenuous sexual assault; the findings were limited to minor bruises with no genital trauma. The Court also noted the established fact of their prior romantic relationship and Lopez’s desire for marriage, which provided context that did not necessarily support the inference of a forcible sexual attempt. When a witness’s testimony on a material point is contradicted by her own prior statements and by physical evidence, it cannot form a sufficient basis for a conviction. Consequently, the evidence presented was too weak and unreliable to sustain a finding of guilt beyond a reasonable doubt.
