GR L 47280; (August, 1990) (Digest)
G.R. No. L-47280 August 20, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DONATO V. TARLAC, accused-appellant.
FACTS
Accused-appellant Donato V. Tarlac was convicted of rape by the Court of First Instance of Caloocan City and sentenced to reclusion perpetua. The conviction rested principally on the testimony of the complainant, Angelita de la Cruz, a 26-year-old woman living with her two children. She alleged that in the early morning of July 13, 1975, Tarlac entered her room, held a knife to her throat, and through force and intimidation, had sexual intercourse with her twice. She claimed her children awoke during the first act, and she told them to go back to sleep. Tarlac admitted the sexual intercourse but claimed it was consensual, asserting they had a prior arrangement for him to visit whenever her common-law husband was absent and that they had engaged in sexual relations on several previous occasions.
ISSUE
Whether the testimony of the complaining witness, standing alone and uncorroborated, is sufficient to sustain a conviction for rape beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted the accused-appellant based on reasonable doubt. The Court acknowledged that rape convictions can rest solely on the victim’s testimony, given the crime’s clandestine nature and the presumption that a woman would not falsely accuse someone of so grave an offense. However, this very circumstance demands the most careful scrutiny of the complainant’s testimony. The Court found Angelita de la Cruz’s account inherently improbable and failing to command the necessary credence for a capital conviction. Key inconsistencies undermined her story: the medico-legal report showed no physical injuries, such as scratches on her neck, which would be expected if a knife was held to her throat throughout two acts of intercourse and a fifteen-minute interval. Furthermore, her act of quieting her crying children instead of using their distress to alert nearby neighbors was deemed unexplainable unless the encounter was consensual. The Court concluded that her version, when objectively scrutinized, created reasonable doubt as to the use of force or intimidation. It was therefore unnecessary to delve deeply into the accused’s version, as the prosecution’s evidence alone was insufficient to prove guilt beyond reasonable doubt.