G.R. No. L-64507 April 25, 1988
THE PEOPLE OF THE PHILIPPINES, petitioner, vs. NESTOR GANDUMA, respondent.

FACTS

The accused-appellant, Nestor Ganduma, was convicted of rape by the Regional Trial Court of Leyte and sentenced to reclusion perpetua. The prosecution’s case, based on the testimonies of the 15-year-old complainant Eva Cornista, her aunt Eugenia Añano, and an examining physician, alleged that on September 8, 1980, Ganduma threatened Cornista with a bolo, dragged her to a nearby bush, and forcibly had carnal knowledge of her. The aunt testified to hearing a scream and witnessing the act. The medical examination revealed linear abrasions on Cornista’s thigh and laxity of the vaginal wall, though her hymen was intact.
The defense presented a starkly different narrative. Ganduma claimed he and Cornista were sweethearts for two years prior. He testified that on the day in question, Cornista invited him to her house and later suggested they go to the bushes to be intimate. They were undressing when the aunt discovered them. Ganduma asserted the sexual act was consensual and that the complaint was filed only after her family found out.

ISSUE

The core issue is whether the prosecution proved the crime of rape beyond a reasonable doubt, specifically the element of force or intimidation and the victim’s lack of consent.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Nestor Ganduma on the ground of reasonable doubt. While the Court typically defers to the trial court’s assessment of witness credibility, it will intervene when the evidence suggests a possible misappraisal. The Court found several circumstances casting doubt on the prosecution’s version. First, the complainant’s alleged tenacious resistance was inconsistent with the medical evidence. She claimed she was dragged, struggled, and fell, causing bruises, yet the physician found no injuries on her arms, legs, or knees—only linear abrasions on her inner thigh, which could be consistent with consensual activity. The absence of corroborative physical injuries for the alleged violent dragging undermined her credibility.
Second, the Court noted an improbability in the narrative: despite the alleged struggle and pain while being dragged a short distance from her house, the victim did not cry out until the actual sexual act, which her aunt then heard. This sequence raised questions about the initial use of force. Third, the defense of a romantic relationship, while uncorroborated, introduced sufficient doubt when juxtaposed with the weak physical evidence of force. The Court emphasized that in rape cases, the conviction must rest on the strength of the prosecution’s evidence, which must prove guilt beyond a moral certainty. Here, the inconsistencies and lack of compelling physical evidence created reasonable doubt as to whether the intercourse was forcible. Consequently, the accused is entitled to an acquittal.