G.R. No. L-5739 / February 24, 1911
THE UNITED STATES, plaintiff-appellee, vs. CANDIDO ESTACIO, defendant-appellant.

FACTS

The defendant, Candido Estacio, was convicted by the Court of First Instance of the crime of attempted rape against Isabel Artillero. The prosecution’s version, based on the testimonies of Isabel and her sister Maria, was that on September 29, 1909, Estacio accosted Isabel under a tree, declared his love, threatened to kill her if she refused, then physically assaulted her, tearing her clothes and bruising her in an attempt to have carnal knowledge. She screamed until her sister Maria came to her aid, causing Estacio to flee. A doctor later found contusions on Isabel’s arm. The defense, supported by Estacio and two other witnesses (Crisela Agoncillo and Cirila Estacio) who were nearby, presented a different account. They testified that Estacio and Isabel had been lovers for about two years, and on that day, they were talking intimately on uneven ground when Estacio accidentally fell onto Isabel during their conversation. Afterward, they all proceeded normally to divide the harvest, and Estacio even visited Isabel’s house the next day.

ISSUE

Whether the evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that Candido Estacio committed the crime of attempted rape.

RULING

No. The Supreme Court REVERSED the judgment of conviction and ACQUITTED the defendant. The Court found the prosecution’s evidence inherently improbable and insufficient to establish guilt beyond reasonable doubt. Key circumstances undermining the charge include: (1) the alleged crime occurred in broad daylight in an open area where other harvesters (the defense witnesses) were nearby and could have seen or heard the struggle; (2) the complainant and the accused had a prior romantic relationship of about two years; (3) their intimate conversation and the accidental fall were consistent with courtship customs; (4) the complainant’s conduct after the incidentimmediately helping with the harvest and not filing a complaint promptlywas inconsistent with a victim of a violent assault; and (5) the accused visited her house the following day without incident. The Court concluded that the facts and circumstances did not support a finding of attempted rape but were more indicative of a consensual romantic encounter. Costs were de oficio.