GR 104678; (July, 1992) (Digest)
March 12, 2026GR L 24371; (April, 1968) (Digest)
March 12, 2026G.R. No. L-49282 July 6, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GILBERT PIZARRO, accused-appellant.
FACTS
Gilbert Pizarro was charged with the rape of Janet Arimboanga on May 22, 1975, in her house in Zambales. Janet, then 17, testified that Gilbert, her former boyfriend from whom she had broken up in April 1975, visited her. While they were alone, he grabbed her, dragged her to the comfort room, and had carnal knowledge of her against her will by force. She claimed she resisted but could not overpower him. After the act, her father arrived. She later reported the incident to her parents, who went to the mayor but did not initially state it was rape. A medical examination the next day revealed a fresh hymenal laceration and a contusion on her buttocks. Gilbert admitted to the sexual intercourse but claimed it was consensual, stating they were still lovers and it was their fifth sexual encounter. He presented love letters and a telegram from Janet to support his claim of an ongoing relationship. The trial court convicted Gilbert of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the accused-appellant, Gilbert Pizarro, is guilty beyond reasonable doubt of the crime of rape committed by force and intimidation.
RULING
The Supreme Court REVERSED the judgment of the trial court and ACQUITTED Gilbert Pizarro. The Court found that the prosecution failed to prove his guilt beyond reasonable doubt. The Court enumerated several reasons for doubting Janet’s account: (1) The evidence suggested their romantic relationship likely continued past the alleged breakup, as they attended events together and met privately. (2) Janet’s behavior was unnatural; she did not prevent her maid from leaving them alone, did not scream or offer fierce resistance, and remained calm after the alleged assault. (3) The physical evidence (the contusion and torn panty) was consistent with consensual sex. (4) Janet was inconsistent in her testimony regarding who left the comfort room first. (5) Her parents did not initially tell the mayor she was raped. The Court concluded that the sexual act was more likely the result of mutual desire and indiscretion rather than a forcible attack.
