GR 71719 20; (May, 1991) (Digest)
G.R. Nos. 71719-20; May 8, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME BACDAD y CAYADING @ “Alaste,” defendant-appellant.
FACTS
The accused-appellant, Jaime Bacdad, was charged with two counts of rape against his 13-year-old mute and slightly deaf cousin, Gina Lanas. The first alleged incident occurred on May 15, 1982, inside a house, and the second on June 9, 1982, inside a barangay health center. The Regional Trial Court acquitted him in the first case but convicted him in the second (Criminal Case No. U-3548), sentencing him to reclusion perpetua. The prosecution’s version of the second incident states that on the evening of June 9, 1982, the appellant lured Gina from a house where she was watching television, gave money to her young niece to leave, and then dragged Gina to a nearby abandoned health center. There, he allegedly pointed a knife at her and had sexual intercourse with her while she struggled. Two girls, Marie Sagudang and Hazel Lanas (Gina’s sister), claimed to have followed and witnessed the act through an opening in the health center wall before running away to report it.
ISSUE
The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape on June 9, 1982, beyond reasonable doubt.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED the appellant based on reasonable doubt. The legal logic centered on the insufficiency of the prosecution’s evidence to meet the required standard of proof beyond reasonable doubt. The Court found the testimonies of the alleged eyewitnesses, Marie and Hazel, contrary to human experience and natural behavior. They claimed to have suspected the appellant’s bad intentions and followed him, yet they did nothing to prevent the alleged dragging of Gina, which occurred very close to other people, nor did they immediately cry for help. Instead, they hid and watched the entire act. This passive demeanor, for witnesses of sufficient age and discernment, cast serious doubt on their claim that a violent rape was occurring. The Court reasoned that their behavior was more consistent with having stumbled upon a consensual encounter, as the appellant had claimed an agreement to marry Gina. In rape cases, the prosecution’s case must stand on its own merits and cannot draw strength from the defense’s weakness. The evidence failed to produce the moral certainty required to overcome the constitutional presumption of innocence. Consequently, the appellant was acquitted.