GR L 30619; (March, 1974) (Digest)
G.R. No. L-30619 March 29, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BEN DAYAG, defendant-appellant.
FACTS
The accused, Ben Dayag, was convicted of rape by the Court of First Instance of Nueva Ecija and sentenced to reclusion perpetua. The prosecution’s case rested solely on the uncorroborated testimony of the complainant, Lourdes Cinense. She alleged that on February 5, 1968, in her hut in Barrio Sta. Catalina, Dayag forcibly had sexual intercourse with her, threatening her with a gun. After the incident, she returned home, informed her husband, and subsequently ingested poison, requiring medical treatment. The defense presented an alibi, claiming Dayag was at the barrio hall working with others, including the complainant’s husband, for most of the day and returned home with a group that included the complainant herself. This alibi was corroborated by Dayag’s wife, but the trial court rejected it.
ISSUE
The sole issue is whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt based on the uncorroborated testimony of the complainant.
RULING
The Supreme Court reversed the conviction and acquitted the accused. The Court emphasized the necessity of exercising the most painstaking care in scrutinizing the testimony in rape cases, as the charge is easy to make but hard to prove. While acknowledging that no woman would lightly concoct a tale repugnant to her virtue, the Court noted that false charges do occur. The Court found several circumstances casting reasonable doubt on the prosecution’s narrative. Notably, the alleged rape occurred in a barrio setting where news travels fast, yet there was no immediate report to the Barrio Captain or the treating physician. The complainant’s own son was reportedly present when she took poison, but no corroborative statement from him was offered. The defense’s alibi, though weak, was supported by his wife and placed the complainant in the accused’s company on the day in question. Given these inconsistencies and the lack of corroboration for the complainant’s serious allegations, the Court held that the evidence failed to meet the required standard of proof beyond reasonable doubt. The constitutional presumption of innocence therefore prevailed.