GR 70305; (December, 1993) (Digest)
G.R. No. 70305 December 15, 1993
People of the Philippines, plaintiff-appellee, vs. Alfredo Nito y Miranda, defendant-appellant.
FACTS
Alfredo Nito y Miranda was charged with the rape of his girlfriend, Melba Llarena, a 20-year-old student. The prosecution’s evidence showed that on October 12, 1973, while Melba was walking home, Nito suddenly appeared, pulled her off the trail, dragged her about five meters, and, despite her shouting and resistance, forced sexual intercourse upon her. Her torn panty and soiled clothes were seen by her mother, leading to a complaint. Medical examinations revealed injuries consistent with forced intercourse, including nail marks, abrasions, hematoma, and hymenal defloration. Nito claimed the intercourse was consensual, asserting they were in a romantic relationship since August 1972, as evidenced by affectionate letters and a prior consensual act on September 7, 1973. He testified that on October 12, they reconciled after a quarrel, mutually agreed to have sex in a secluded area below the trail, and were discovered by a passerby. The trial court convicted Nito, giving full credence to Melba’s testimony and noting his sworn statement to the police where he admitted he “forced her.”
ISSUE
Whether the prosecution proved beyond reasonable doubt that Alfredo Nito y Miranda committed rape through force and intimidation against the will of Melba Llarena.
RULING
The Supreme Court REVERSED the trial court’s decision and ACQUITTED Alfredo Nito y Miranda. The Court found that the prosecution failed to prove his guilt beyond reasonable doubt. Key points included: the medical findings were inconclusive as to whether the injuries resulted from force or consensual intercourse; the testimony of the alleged eyewitness, Juan Nolasco, was unreliable and did not corroborate force; the complainant’s conduct after the alleged rape (e.g., not immediately reporting it, walking home with the accused) was inconsistent with a lack of consent; and the trial court improperly relied on Nito’s sworn statement without considering the context of its extraction. The Court emphasized that while the accused’s defense of consensual intercourse was weak, the prosecution’s evidence was weaker and insufficient to overcome the constitutional presumption of innocence. Moral certainty of guilt was lacking.