G.R. No. 90318 July 24, 1992
People of the Philippines, plaintiff-appellee, vs. Porferio Ignacio, defendant-appellant.

FACTS

The defendant-appellant, Porferio Ignacio, was charged with the rape of his daughter, Paulina Ignacio Galan, a 26-year-old widow. The information was filed on January 14, 1987. Paulina testified that her father raped her twice in their house in Anahawan, Southern Leyte, on June 8, 1986. She claimed the first rape occurred around 8:00 PM while her mother was at a wake. She alleged her father pointed a bolo at her, pulled off her panty, and forcibly mounted her, threatening to kill them all if she reported it. Her testimony regarding the second rape was inconsistent, initially stating it happened shortly after the first before her mother’s return at 9:00 PM, but later stating on cross-examination it occurred at 8:00 AM the following morning. Porferio Ignacio denied the charge, asserting Paulina was still in Manila on that date and that her accusation stemmed from his refusal to let her stay in his house due to her behavior, inferring another man caused her pregnancy. The Regional Trial Court found the accused guilty and sentenced him to reclusion perpetua and ordered him to pay civil indemnity.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant, Porferio Ignacio, for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court REVERSED the decision of the trial court and ACQUITTED the accused-appellant on the ground of reasonable doubt. The Court found the testimony of the complaining witness, Paulina, replete with material inconsistencies that seriously undermined her credibility. These inconsistencies pertained to: whether she resisted or submitted meekly; whether she was alone or her children were present during the first rape; the timing of the second rape and her mother’s return; the date she reported the rapes to the police versus the date of her sworn statement; and whether she left her parents’ house immediately after the incident. The Court held these were not minor inconsistencies but cast reasonable suspicion on her veracity. The narration of the second rape, which the Court found completely unbelievable, discredited her entire testimony. The defense of denial, while weak, was sufficient given the prosecution’s failure to meet the burden of proving guilt beyond reasonable doubt. The constitutional presumption of innocence must prevail where the evidence for the prosecution is insufficient.