G.R. No. L-43805 October 23, 1982
People of the Philippines, plaintiff-appellee, vs. Gregorio Romero, Jr., defendant-appellant.

FACTS

The appellant, Gregorio Romero, Jr., was convicted of rape by the Court of First Instance of Pampanga and sentenced to life imprisonment. The conviction was based primarily on the testimony of the complainant, Luz Medina, a seventeen-year-old. She alleged that in mid-June 1970, while staying at her aunt’s house, the appellant entered at midnight, threatened her, and succeeded in having carnal knowledge against her will. She claimed this occurred despite her resistance and that she remained silent for months out of fear of the appellant’s death threats, only revealing the incident after a medical examination confirmed her pregnancy, which resulted in childbirth in March 1971.
The appellant presented a denial, asserting he was employed in Angeles City and had not visited the complainant’s aunt’s house since 1968. He also pointed to rumors suggesting another individual was the father of the child. The defense highlighted inconsistencies in the complainant’s account and her conduct following the alleged assault.

ISSUE

Whether the prosecution evidence, anchored solely on the complainant’s testimony, is sufficient to overcome the constitutional presumption of innocence and prove the appellant’s guilt beyond reasonable doubt.

RULING

The Supreme Court acquitted the appellant. The legal logic centered on the requirement that evidence for conviction must be credible and consistent. The Court meticulously scrutinized the complainant’s testimony, finding it lacking the requisite credibility to sustain a conviction.
Key inconsistencies were fatal to the prosecution’s case. A material discrepancy existed between her sworn statement, where she claimed she was rendered unconscious by a blow before the act, and her court testimony, where she stated she was conscious throughout. This inconsistency pertained to a central fact of the alleged crime. Furthermore, the Court found her post-incident conduct unnatural and contrary to human experience. She allegedly regained composure within minutes to falsely tell her aunt she had merely urinated, and she remained silent for eight months despite multiple alleged subsequent rapes, even as her pregnancy became apparent. Such behavior was deemed incompatible with the natural reaction of an outraged victim.
The Court emphasized that in rape cases, the testimony of the complainant must be scrutinized with extreme care. When such testimony is inconsistent on material points and contradicted by ordinary human behavior, it fails to meet the standard of proof beyond reasonable doubt. Consequently, the constitutional presumption of innocence prevailed, warranting acquittal.