GR 6740; (September, 1911) (Digest)
G.R. No. 6740, September 1, 1911
THE UNITED STATES vs. PRIMO SAMONTE
FACTS
The defendant-appellant, Primo Samonte, was convicted by the Court of First Instance of La Laguna for the crime of rape against Epifania Abadines, a deaf-mute. The prosecution alleged that on August 24, 1909, Samonte entered the house of Abadines’ stepfather, forcibly threw her to the floor, and had sexual intercourse with her despite her resistance. Key prosecution witnesses included Matea Pacheco, who claimed to have witnessed the act; Canuto Aquino, who testified to seeing Epifania crying and disheveled after the incident; and Fabiana Abadines, Epifania’s mother, who reported her daughter’s account. A physician’s testimony regarding recent sexual intercourse was undermined on cross-examination. The defense presented Samonte, who testified that he visited the house only to deliver money to Epifania’s stepfather, briefly interacted with Epifania, and later cut bamboo outside the house. His account was corroborated by witnesses Segundo Lagradilla, Anacleto Ladiana, and Maria Flores, who also testified to existing enmity between Matea Pacheco and Samonte’s mother due to a debt dispute. The defense highlighted Epifania’s calm demeanor after the alleged incident, including her sweeping the house and going to wash clothes with another girl, as inconsistent with a recent violent assault.
ISSUE
Whether the prosecution’s evidence is sufficient to prove beyond reasonable doubt that Primo Samonte committed the crime of rape.
RULING
No. The Supreme Court reversed the trial court’s judgment and acquitted Samonte. The Court found that the evidence failed to establish guilt beyond reasonable doubt. Key reasons included: (1) The physician’s testimony was discredited on cross-examination; (2) The torn and bloody garments allegedly resulting from the rape were not presented as evidence; (3) The testimony of Matea Pacheco was suspect due to proven ill will toward Samonte’s family; (4) The behavior of Epifania and Samonte after the alleged incidentsuch as Samonte calmly borrowing a bolo, cutting bamboo, and returning the tool, and Epifania proceeding with ordinary chores without apparent distresswas inconsistent with a recent violent rape; and (5) Witness Segundo Lagradilla’s testimony contradicted the prosecution’s timeline and supported Samonte’s account. The Court concluded that the evidence raised a clear doubt as to Samonte’s guilt, warranting acquittal.
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