Case Digest (G.R. No. 103800)
Facts:
People of the Philippines v. Augusto Ching, G.R. No. 103800, January 19, 1995, Supreme Court Second Division, Regalado, J., writing for the Court.The prosecution filed an information for rape on April 6, 1990, in the Regional Trial Court of Palawan and Puerto Princesa City, Branch 51 (Criminal Case No. 8578), based on the sworn complaint of ten‑year‑old Maria Theresa Decolongon. On June 11, 1990, accused‑appellant Augusto Ching was arraigned and pleaded not guilty. Trial ran from July 25 to October 31, 1990. On April 2, 1991, the trial court convicted appellant of rape and sentenced him to reclusion perpetua with accessory penalties of civil interdiction and perpetual absolute disqualification, ordered payment of P40,000.00 moral damages, and costs.
At trial, the complainant testified that on the night of December 14, 1989, while she and her younger brother slept alone at home, someone (later identified as appellant) covered her nose and mouth, slapped her, and she lost consciousness; upon regaining consciousness she found appellant on top of her with his shorts lowered and felt his penis inserted in her — and later saw blood on her underwear. She immediately told neighbor Teofisto Labarosa, who did not intervene. Maria delayed reporting the incident to her parents because they had left earlier that night after her mother was injured; she later told relatives and on January 13, 1990 underwent medico‑legal examination by Dr. Ofelia O. Reyes, who found a healed hymenal laceration at 2:00 and 10:00 o'clock positions, “probably caused by sexual intercourse,” and consistent with an injury three to four weeks earlier.
Appellant testified he spent the evening playing mahjong with friends, later went to a dance and drank until early morning, and denied committing the assault; he offered a version that he hid outside Maria’s house and later entered only to steal a rooster and then went to the dance. He also suggested the family had mo...(Pro-only)
Issues:
- Did the trial court gravely abuse its discretion in relying on the uncorroborated testimony of the complainant to convict appellant?
- Did the defense present positive evidence that negated the occurrence of the alleged rape or otherwise sufficiently rebut the prosecution’s case?
- Was appellant’s constitutional presumption of innocence...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)