G.R. No. 94554 February 19, 1993
People of the Philippines, plaintiff-appellee, vs. Anacleto Colcol, Jr., accused-appellant.

FACTS

Anacleto Colcol, Jr. was accused of raping his 14-year-old neighbor, Nora Escalona, three times in March 1986. Nora testified that each rape occurred at around 6:30 AM on a usually busy barangay road in Barangay Sobol, Asingan, Pangasinan, which was inexplicably empty each time. Anacleto allegedly dragged her into nearby bushes, threatened her with a balisong, kicked her to remove her panty, and raped her. She did not report the incidents due to death threats. Nora claimed she became pregnant as a result, but her parents only discovered her pregnancy on the day she delivered the baby on December 4, 1986. The child was named Joel Escalona Colcol and died five weeks later. The prosecution presented medical evidence only as to the delivery and estimated conception date. Anacleto presented an alibi, testifying he was in Lumayao, San Quintin, Pangasinan, from February to April 1986, attending to the family duck farm with his live-in partner (later wife), a claim corroborated by witnesses. The defense also insinuated Nora was promiscuous and that her father attempted to withdraw the complaint for P30,000. The trial court convicted Anacleto, giving credence to Nora’s testimony.

ISSUE

Whether the prosecution’s evidence is sufficient to prove the guilt of Anacleto Colcol, Jr. beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Anacleto Colcol, Jr. The Court found the complainant’s testimony replete with improbabilities and inconsistencies that created reasonable doubt. These included: the unlikely coincidence of the usually busy road being deserted on all three occasions; the implausibility of Nora willingly taking the same route and being raped three times in weekly succession; the unnatural claim that her parents, living with her, did not notice her pregnancy until the day of delivery; the curious detail that her panty was removed by being kicked; the rapes allegedly occurring in broad daylight; and Nora’s enrollment in two schools while pretending to attend classes. The Court emphasized that the constitutional presumption of innocence must be overcome by proof beyond reasonable doubt, which the prosecution failed to provide. The weakness of the defense’s alibi does not relieve the prosecution of its burden to prove guilt based on strong and credible evidence.