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
Case Digest (G.R. No. 74352)
Facts:
The case involves Elpidio Cabading as the accused-appellant and the People of the Philippines as the plaintiff-appellee. The events leading to the case occurred on August 8, 1978, in Brgy. Naguilian, La Union, where the complainant, Benita Huliganga, was staying at her grandfather's house along with her siblings while her husband was away. Around 10:00 PM, while breastfeeding her child, Benita heard someone push the door, mistakenly believing it was her husband. When the intruder raised her mosquito net, she recognized him as Elpidio Cabading, a neighbor, aided by a kerosene lamp in the room. Cabading then covered her mouth with his palm, climbed on top of her, and proceeded to sexually assault her by inserting his penis into her vagina. Despite her attempts to resist, she was unable to extricate herself due to Cabading's strength and weight. He threatened her with harm if she revealed the incident. After the assault, Benita moved to her other grandfather's house and reported the incident to her family the following morning, leading to a police report and medical examination. The medical examination revealed no external signs of spermatozoa or physical injuries, except for a minor abrasion on her face, which a medical expert suggested could have been caused by Cabading covering her...