Title
People vs. Dela Cruz
Case
G.R. No. 92442-43
Decision Date
Mar 23, 1992
A 15-year-old alleged rape by Nestor de la Cruz in 1988 and 1989; inconsistencies in testimony and lack of credible evidence led to his acquittal by the Supreme Court.

Case Digest (G.R. No. 92442-43)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Two separate complaints were filed on July 26, 1989, by Remedios Centeno y Lagrosa, a 15-year-old minor, assisted by her mother.
    • Both complaints charged Nestor dela Cruz with two counts of rape, alleging that the sexual intercourse was non-consensual and committed with the use of a deadly weapon (a knife).
  • Allegations in the Complaints
    • First Complaint (Criminal Case No. 33236)
      • Date & Time: Allegedly occurred on or about May 8, 1989 at around 8:00 p.m. in Kalookan City, Metro Manila.
      • Details of the Incident:
        • The complainant went to the accused’s residence due to the insistence of her mother for a denture fitting.
ii. Upon arrival, the accused allegedly pulled her inside, threatened her by poking a knife at her neck, and forced her to lie down on the floor. iii. He is alleged to have removed her clothing and then kissed, embraced, orally stimulated, and inserted his private organ, with additional mention of finger insertion.
  • Second Complaint (Criminal Case No. C-33237)
    • Date & Time: Allegedly occurred on or about June 20, 1988 in Kalookan City, Metro Manila.
    • Details of the Incident:
      • The complainant went to the accused’s residence, ostensibly to inquire about a karate tournament scheduled for the following day.
ii. The accused invited her to the house of a certain Mang Romy, which was a two-storey structure supposedly located two houses away from his own residence. iii. At Mang Romy’s house, she was allegedly led upstairs where the accused allegedly threatened her with a knife impaled at her neck, forced her onto a folding bed, removed her clothing, and executed a series of sexual acts including kissing, undressing, and intercourse.
  • Prosecution’s Narrative and Witness Testimony
    • The prosecution summarized the incidents by detailing:
      • The accused’s use of a deadly weapon (knife) to intimidate the victim.
      • The sequence of events that involved him forcibly removing her clothing and engaging in sexual contact.
      • The victim’s account of being forced to remain silent by threats of death if she screamed.
    • The complainant’s detailed direct testimony included:
      • A first incident with a demonstration of how the accused threatened her and forced her to lie down on a folding bed.
      • A meticulous recitation of the acts committed by the accused, including the removal of her t-shirt, bra, shorts, and panty, as well as the progression of physical contact.
      • A second incident paralleling the first, with minor differences in location and circumstances (inside the accused’s own house) yet same use of a knife and a series of non-consensual sexual acts.
  • Defense Case and Accused’s Testimony
    • The accused consistently maintained his plea of not guilty and denied having sexual intercourse with the minor on both occasions.
    • He argued against the possibility of the alleged events for several reasons:
      • The physical impossibility of committing the crime in Mang Romy’s house, as testified by defense witnesses who described the second floor as an open, un-walled area visible from the street.
      • The improbability of using his own house—where his family and students were present—to commit a similar act without being detected.
    • His alibi was supported by:
      • Testimony from his wife, Josefina dela Cruz.
      • Testimonies from Aurora Nielo (a barangay tanod resident) and one of his karate students, Charlina Garnudo.
  • Trial Court Decision and Points Raised on Appeal
    • The trial court found Nestor dela Cruz guilty beyond reasonable doubt on both counts of rape and sentenced him to double reclusion perpetua plus payment of damages.
    • On appeal, the accused contended:
      • The prosecution’s evidence was neither competent nor sufficient to establish guilt beyond reasonable doubt.
      • The credibility of the complainant’s testimony was challenged on the basis that it was unnatural, rehearsed, and inconsistent with expected behavior in a rape incident.
      • The similarities between the two incidents suggested prearranged or rehearsed accounts rather than spontaneous testimonies of forced violence.

Issues:

  • Main Issue Presented in the Appeal
    • Whether the evidence, particularly the credibility of the complainant’s testimony, was legally sufficient to convict the accused beyond reasonable doubt.
    • Whether the alleged similarities and apparent rehearsals in the complainant’s accounts diminished her credibility, thereby warranting acquittal.
  • Specific Points of Contention
    • The physical and circumstantial inconsistencies in the victim’s testimony regarding:
      • The condition and structure of Mang Romy’s house (e.g., a two-storey structure with no walls on the second floor).
      • The improbability of committing a crime under such conspicuous and observable conditions.
    • The defense’s argument regarding:
      • The absence of demonstrable force or clear evidence of intimidation that would normally preclude any form of resistance by the victim.
      • The inconsistencies between the victim’s testimonies during trial and statements made prior to the inquest fiscal.
    • The delay in the victim’s immediate reporting of the incidents and the nonchalance of her parents upon learning of the events.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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