Title
People vs. Cabading
Case
G.R. No. 74352
Decision Date
Jun 6, 1989
The court acquitted the appellant due to insufficient evidence and significant doubts regarding the credibility of the complainant's testimony in the rape allegation.
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Case Digest (G.R. No. 74352)

Facts:

  • Elpidio Cabading is the accused-appellant; the People of the Philippines is the plaintiff-appellee.
  • The incident occurred on August 8, 1978, in Brgy. Naguilian, La Union.
  • Complainant Benita Huliganga was at her grandfather's house with her siblings while her husband was away.
  • At around 10:00 PM, while breastfeeding, Benita heard a noise at the door, thinking it was her husband.
  • She recognized Elpidio Cabading, a neighbor, when he raised her mosquito net.
  • Cabading covered her mouth, climbed on top of her, and sexually assaulted her.
  • Despite her resistance, Benita could not escape due to Cabading's strength.
  • He threatened her not to disclose the incident.
  • The next morning, she reported the assault to her family, leading to a police report and medical examination.
  • The medical exam showed no spermatozoa or significant injuries, only a minor facial abrasion.
  • Cabading claimed an alibi, stating he was home with his family during the incident.
  • The Regional Trial Court convicted Cabading of simple rape, sentencing him to reclusion perpetua and ordering indemnification to the victim.
  • Cabading appealed the conviction.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed and set aside the Regional Trial Court's decision, acquitting...(Unlock)

Ratio:

  • The Supreme Court highlighted the necessity for extreme caution in rape cases due to the severe penalties and the risk of wrongful conviction.
  • The evidence from the complainant did not meet the standard of moral certainty required for a conviction.
  • Doubts arose from the complainant's lack of evident resistance during the assault, which was inconsistent with typical victim behavior.
  • The complainant did not shout or struggle significantly, raising questions about her credibility.
  • The assertion that Cabading held a knife was co...continue reading

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