G.R. No. L-54221. January 30, 1982.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO ESTACIO alias Narding, defendant-appellant.

FACTS

The accused-appellant, Leonardo Estacio, was charged with rape under Article 335 of the Revised Penal Code. The Information alleged that on May 20, 1968, in Sto. Tomas, La Union, Estacio, armed with a knife, had sexual intercourse with Teresita Ramirez Laceste while she was asleep and unconscious. Upon awakening, he allegedly continued the act through force and intimidation. The trial court convicted Estacio and sentenced him to an indeterminate penalty. The case was elevated to the Supreme Court for review due to the imposable penalty under the applicable law.
The prosecution’s case rested primarily on the testimony of the complainant, Teresita Laceste. She testified that she awoke to find Estacio on top of her, identified him by his beard, and was threatened with death. She claimed he was armed. After the incident, she reported it to an old woman in her house. The defense highlighted inconsistencies, including her admission in a sworn statement that she had sexual intercourse with her husband just two hours after the alleged rape.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED the accused-appellant. The Court emphasized that in rape cases, given the severity of the penalty and the nature of the accusation, the evidence for conviction must be clear, convincing, and must survive the test of moral certainty to overcome the constitutional presumption of innocence. The testimony of the offended party must be scrutinized in light of human nature and experience.
The Court found that the prosecution failed to meet this exacting standard. Several circumstances detracted from the credibility of the complainant’s testimony. First, her act of having sexual intercourse with her husband merely two hours after the alleged rape was deemed completely contrary to human nature and experience, casting serious doubt on the veracity of her claim. Second, her testimony was erratic and inconsistent, particularly regarding whether the accused was armed with a knife or a gun. Third, the trial court’s factual findings were deficient, as the judge who rendered the guilty verdict did not personally hear the testimonies of the complainant and most prosecution witnesses, relying instead on the record. The Court held that the evidence did not overcome the presumption of innocence, as there were substantial facts of substance and value that militated against a finding of guilt. Consequently, the accused was acquitted.