Title
People vs. Amarela
Case
G.R. No. 225642-43
Decision Date
Jan 17, 2018
AAA accused Amarela and Racho of rape in 2009. Despite medical findings of hymen lacerations, the Supreme Court acquitted both due to inconsistencies in AAA’s testimony, lack of corroborative evidence, and reasonable doubt.

Case Digest (G.R. No. 235725)
Expanded Legal Reasoning Model

Facts:

  • Informations and Parties
    • Accused-Appellants: Juvy D. Amarela and Junard G. Racho.
    • Plaintiff-Appellee: People of the Philippines.
    • Two Informations filed in Davao City RTC, Branch 11:
      • Crim. Case No. 64,964–09 (Amarela charged with rape on Feb. 10, 2009).
      • Crim. Case No. 64,965–09 (Racho charged with rape on Feb. 11, 2009).
  • Prosecution Evidence
    • AAA, single housekeeper, testified she was pulled from a beauty contest area to a makeshift stage under a day-care center by Amarela, punched, undressed, and raped.
    • After the first attack she fled, sought help, was escorted by Racho against her will into a shanty, boxed in the abdomen, undressed, and raped.
    • She reported to police the next day and accused were arrested.
  • Defense Evidence
    • Amarela claimed he drank, fell unconscious, and had no recollection of any assault.
    • Racho testified he merely accompanied AAA home at his mother’s behest and left when she insisted on going further; he denied any carnal act, citing an impaired left arm.
    • Medical certificate corroborated Racho’s arm injury; his mother confirmed he escorted AAA then returned home without incident.
  • Proceedings Below
    • RTC (26 June 2012) found AAA’s testimony credible, convicted both of rape, imposed reclusion perpetua and awarded P50,000 civil indemnity and P50,000 moral damages each.
    • CA (17 February 2016) affirmed, upholding positive identification doctrine and victim’s credibility, rejecting appellants’ arguments on darkness, lack of medical injuries, and improbability of double rape.

Issues:

  • Whether the prosecution proved beyond reasonable doubt that Amarela and Racho raped AAA.
  • Whether AAA’s lone testimony, given inconsistencies, identification difficulties, physical impossibilities under the stage, and inconclusive medical findings, satisfies the moral certainty standard.
  • Whether Racho’s denial and alibi deserve weight to raise reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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