G.R. No. 92442 -43, March 23, 1992
The People of the Philippines vs. Nestor Dela Cruz

FACTS

The accused-appellant, Nestor de la Cruz, was charged with two counts of rape allegedly committed against Remedios Centeno, a 15-year-old, on June 20, 1988, and May 8, 1989. The prosecution’s narrative, as summarized by the trial court, stated that in both incidents, the accused used a knife to intimidate the victim into submission. The first rape allegedly occurred in a house with incomplete walls when the victim went to inquire about a karate tournament. The second allegedly happened at the accused’s residence when the victim went for a denture fitting. The accused denied the charges, presenting an alibi and witnesses to testify that the locations described were either a barangay outpost with frequent activity or his own home where students and his wife were present on the relevant dates. The trial court convicted the accused, sentencing him to double reclusion perpetua.

ISSUE

The central issue is whether the prosecution’s evidence, primarily the testimony of the complainant, proved the accused’s guilt of rape beyond reasonable doubt, specifically whether force or intimidation was sufficiently established.

RULING

The Supreme Court reversed the conviction and acquitted the accused-appellant. The Court found that the evidence failed to prove the element of force or intimidation beyond reasonable doubt. The complainant’s testimony was deemed insufficient and created reasonable doubt. The Court noted the unnatural uniformity in her account of the two separate incidents, suggesting rehearsal. Crucially, her behavior was inconsistent with that of a victim who had been forcibly ravished. She returned to the accused’s house for the second alleged incident without reporting the first, failed to demonstrate any effort to resist or cry for help during the assaults, and only disclosed the events casually during a “girls’ talk,” using the term “ginalaw” rather than “ginahasa.” Furthermore, a material discrepancy existed between her trial testimony and her sworn statement regarding her reason for going to the accused’s house on the second occasion. The Court held that while sexual intercourse may have occurred, the prosecution did not present convincing and uninterrupted proof that it was achieved through force or intimidation, which is essential for a rape conviction.