G.R. No. 117378 - Capili vs. National Labor Relations Commission

The case involves an appeal filed by Vincent Garrido y Elorde from the decision of the Regional Trial Court (RTC) of Las Pias City, which found him guilty of rape, later affirmed with modifications by the Court of Appeals.
The RTC rendered its decision on 12 September 2007 in Criminal Case No. 04-0931, and the Court of Appeals confirmed this decision on 20 October 2009 with a reduction in the award for civil indemnity.

On or about 20–21 October 2004 in the City of Las Pias, the accused, along with other individuals (AAA, BBB, and Vernel), was involved in events that led to the charge of rape.
According to the prosecution’s account, after a drinking session following an invitation to what was initially presented as a birthday party, the group went to Garrido’s house where AAA, who was allegedly intoxicated, was left in a room with conflicting circumstances.
The victim AAA testified that in a state of physical weakness and mental confusion, she was forcibly engaged in multiple acts of sexual intercourse by Garrido. The accused is said to have turned off the light, removed her clothes, and, despite her resistance, forcibly consummated the act multiple times over the course of the night and into the early hours of the following day.

AAA, the complainant, provided detailed but at times inconsistent narrations of events inside Garrido’s house, including her state of intoxication, physical resistance, and subsequent actions.
Medical evidence was presented by Dr. Bonnie Yap Chua, who noted physical findings on AAA’s body (ecchymosis on the breast area and deep healed lacerations on the hymen) consistent with forceful contact.

Garrido’s version was corroborated by his companions—Vernel, Vivence (his brother), and his mother Walita—who testified that the events inside the house were consensual, noting that AAA appeared only slightly intoxicated and engaged in sexual intimacy with Garrido.
These witnesses stated that AAA willingly participated in sexual acts, as evidenced by her conduct and clear speech in the morning after the incident.

AAA’s testimony was marked by significant discrepancies between her direct examination and her cross-examination. Specific inconsistencies involved:

Whether she voluntarily stayed in the room or was forcibly pulled inside.
The exact presence and role of the other occupants (BBB and Vernel) during the occurrence of the rape.
Her physical reactions during the incident, including her inability to resist due to shock or as a result of being in an altered state.

Additional inconsistencies arose from the alleged involvement of her sister, CCC, whose separate account of a similar previous rape by the accused and the purported plan to “entrap” Garrido, raised doubt as to the veracity of the claims.

The RTC found Garrido guilty beyond reasonable doubt based largely on the credibility of AAA’s detailed account despite her intoxication and physical exhaustion.
The Court of Appeals affirmed the RTC ruling, placing emphasis on the inability to require a standard reaction from rape victims and dismissing the defense’s narrative of consensual conduct.

Whether the testimony of AAA, as the sole complainant, was sufficiently credible despite noticeable inconsistencies in her narration.
How the conflicting accounts between the prosecution’s and defense’s witnesses should be weighed in determining the truth of whether the sexual act was consensual or accomplished through force.

Whether the prosecution’s evidence, particularly the physical and testimonial evidence, met the burden of proving guilt beyond reasonable doubt.
Whether the presence of inconsistencies in AAA’s statement, including the sequence of events and her reactions, created a reasonable doubt as to the non-consensual nature of the sexual acts.

The issue of whether the private nature of the alleged crime allows the lone testimony of the victim to suffice in establishing guilt, or if the defense’s corroborative evidence should outweigh or significantly diminish the probative value of the victim’s account.