G.R. No. L-79677 November 28, 1988
People of the Philippines, plaintiff-appellee, vs. Victor Mejias, accused-appellant.

FACTS

The accused-appellant, Victor Mejias, was convicted by the Regional Trial Court of Tagbilaran City of the crime of rape against Ruena Dolmeguez, a twelve-year-old girl. The prosecution alleged that on May 31, 1986, in Barangay Tungod, Inabanga, Bohol, Mejias entered the victim’s house, employed force and intimidation by boxing her head and biting her neck, and forcibly attempted to have sexual intercourse with her. The victim testified that she struggled and shouted during the assault. She reported the incident to her mother later that evening, leading to a medical examination and the filing of a complaint.
The defense presented a contrasting version. A witness, Anita Minguito, testified that she saw the victim and her mother on the day of the alleged incident. According to Minguito, the victim’s mother was pinching the girl while stating the girl was “erotic” and had been raped, and it was Minguito who advised them to report to the barangay captain. The defense highlighted inconsistencies, noting the victim was allegedly seen selling cigarettes shortly after the traumatic event and that the medical examination revealed no external injuries on her head or body despite her claim of being struck and struggling violently.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond a reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Victor Mejias on grounds of reasonable doubt. The Court acknowledged the general rule of deferring to the trial court’s assessment of witness credibility but found compelling reasons to depart from it in this case. The Court’s legal logic centered on the insufficiency of the evidence to meet the stringent standard of proof beyond reasonable doubt required for a criminal conviction.
The testimony of the complainant was found to lack credibility and was uncorroborated by the physical evidence. The medical certificate issued nine hours after the incident showed no signs of physical injuries on the victim’s head or body, which contradicted her detailed account of being boxed, struggling intensely, and having her panty forcibly torn. This absence of corroborative physical evidence undermined the claim that force and violence were employed. Furthermore, the defense witness’s testimony introduced reasonable doubt by suggesting an alternative narrative for the complaint’s origin. The Court emphasized that between a positive testimony fraught with inconsistencies and a denial supported by circumstances casting doubt, the latter must prevail when it creates reasonable doubt. Consequently, the evidence failed to establish guilt with the requisite moral certainty, warranting acquittal.