G.R. No. L-38423 November 25, 1982
People of the Philippines vs. Samuel Pimentel

FACTS

The appellant, Samuel Pimentel, was convicted of rape and sentenced to reclusion perpetua by the Court of First Instance of Misamis Oriental. The conviction was based on the testimony of the complainant, his sister-in-law Lina Sabejon, who alleged that on September 27, 1969, Pimentel threatened her with a revolver inside his jeepney, immobilized her, and had carnal knowledge against her will. She reported the incident 39 days later. Pimentel admitted to sexual intercourse but claimed it was consensual, asserting it was part of an ongoing illicit relationship. He presented an affidavit of desistance executed by the complainant, which recanted her accusation.

ISSUE

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

RULING

The Supreme Court acquitted the appellant. The Court emphasized the legal principle that an accusation for rape is easy to make but hard to prove, and harder to defend against even for an innocent person. The prosecution’s evidence was deemed insufficient to overcome reasonable doubt. The Court found the complainant’s conduct after the alleged incident incompatible with that of a victim of a violent rape; she displayed no immediate hysteria, continued her normal routine for over a month, and only filed a complaint after seeking advice from a priest and her uncle. The medical findings, which indicated the complainant had likely had prior sexual experiences, corroborated the appellant’s claim of a previous consensual relationship. While affidavits of desistance are generally viewed with disfavor, the Court ruled that the special circumstances of this case—including the delay in reporting, the complainant’s behavior, and the medical evidence—created serious doubt about the appellant’s guilt. Coupled with the retraction, these circumstances justified overturning the conviction.