GR 51449; (December, 1989) (Digest)
G.R. No. 51449 December 20, 1989
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO HIZON, defendant-appellant.
FACTS
The prosecution alleged that Ricardo Hizon raped the deaf-mute complainant, Maria Cristina Cabanero, on January 25, 1976, at a fair in Caloocan City. Cristina testified that she and her friend, Marilou Castillo, entered a booth where Hizon approached, touched her, and later, after Marilou left, forced himself on her, rendering her unconscious. She reported the rape only in April 1976, after suffering a miscarriage. Hizon was identified by Cristina in a police lineup. The defense presented an alibi, asserting Hizon was in Pasig for his daughter’s baptism at the time of the alleged crime. Corroborative witnesses, including family and the parish registrar, supported his presence in Pasig. The defense also claimed the complainant’s mother offered to withdraw the case for a cash settlement.
ISSUE
Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Ricardo Hizon. The Court held that the prosecution failed to meet the stringent standard of proof beyond reasonable doubt required to overcome the constitutional presumption of innocence. The complainant’s testimony was found implausible and inconsistent with natural human behavior; for instance, she did not immediately leave the booth when accosted and delayed reporting the incident for months without a credible explanation for her fear. The Court noted the absence of medical proof of rape or corroboration from her companion, Marilou Castillo, who allegedly witnessed the initial acts. The defense’s alibi, supported by several witnesses and a baptismal certificate, was deemed credible and not physically impossible, as the distance between Pasig and Caloocan City was negotiable. The trial court erroneously held Hizon’s pre-trial silence during police investigation against him, as such silence is a constitutional right. The unrebutted allegation of a settlement offer further cast doubt on the prosecution’s motives. Consequently, the evidence for the prosecution was deemed weak and insufficient to sustain a conviction, warranting acquittal.