G.R. No. 82303 December 21, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. RODRIGO PASCUA, accused-appellant.

FACTS

The accused-appellant, Rodrigo Pascua, was convicted by the Regional Trial Court of rape and sentenced to reclusion perpetua. The information alleged that in November 1982, in Gabaldon, Nueva Ecija, Pascua, by force and intimidation with a bayonet, had carnal knowledge of Magdalena Cambaleza, then less than twelve years old. Magdalena, the daughter of Pascua’s common-law wife Agnes, lived with them. She testified that after the 1982 incident, she was sent to work elsewhere but was later fetched by Pascua in March 1984 under the pretext of her mother’s illness. He instead brought her to Nueva Vizcaya and San Jose City, where he raped her again on two occasions, threatening her with a bayonet. Magdalena eventually reported the rapes, leading to Pascua’s arrest. The medical examination confirmed the loss of physical virginity but noted no fresh injuries.
The defense consisted solely of Pascua’s testimony, denying all allegations. He claimed Magdalena’s mother, Agnes, orchestrated the charges due to a quarrel. He presented letters allegedly written by Agnes to him, which the prosecution claimed were his own pleas for forgiveness. The defense highlighted inconsistencies in the prosecution’s timeline, such as when Magdalena’s family began living with Pascua and the delayed medical examination conducted seventeen months after the alleged first rape and weeks after the second.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Rodrigo Pascua. The Court found that the prosecution failed to meet the required quantum of proof beyond reasonable doubt. The testimony of the complainant was fraught with inherent improbabilities and inconsistencies that eroded its credibility. The Court noted the unnatural behavior of the complainant’s mother, Agnes, who, despite allegedly knowing of the 1982 rape, continued to cohabit with the accused, sent her daughter away instead of immediately reporting the crime, and only acted after the 1984 incidents. This delay and conduct were contrary to human nature and cast doubt on the veracity of the charges.
Furthermore, the medical evidence was inconclusive, merely proving loss of virginity but not the circumstances or timeframe, thus failing to corroborate the specific allegations of forcible rape. The alleged letters of apology from the accused were also deemed unreliable due to conflicting interpretations by the parties. The Court emphasized that in rape cases, the accusation must be supported by credible and convincing evidence. The evidence presented was insufficient to overcome the constitutional presumption of innocence. The prosecution’s narrative contained gaps and implausibilities that created reasonable doubt, necessitating acquittal.