Title
Baleros, Jr. vs. People
Case
G.R. No. 138033
Decision Date
Feb 22, 2006
Petitioner charged with attempted rape in 1991; circumstantial evidence pointed to his presence, but Supreme Court acquitted him, finding acts insufficient for rape, convicting instead for light coercion due to unjust vexation.

Case Summary (G.R. No. 217722)

Petitioner

Renato D. Baleros, Jr., charged with attempted rape under Criminal Case No. 91-101642 before the RTC of Manila, Branch 2.

Respondent

People of the Philippines.

Key Dates and Procedural History

December 12–13, 1991: Alleged attempted rape in Room 307, Celestial Marie Building.
December 17, 1991: Information for attempted rape filed.
February 5, 1992: Arraignment; “Not Guilty” plea.
December 14, 1994: RTC conviction for attempted rape; sentence of 4 years, 2 months & 1 day to 10 years prision mayor plus damages.
January 13, 1999: CA decision affirmed RTC.
March 31, 1999: CA denied motion for reconsideration.
February 22, 2006: SC decision on petition for review.

Applicable Law

1987 Philippine Constitution (presumption of innocence, right to information of charges).
Revised Penal Code:
• Article 335 on rape;
• Article 6 on attempt;
• Article 287 (2nd paragraph) on light coercion.
Rules of Court, Rule 133, Section 4 (circumstantial evidence).

Prosecution’s Evidence

• Malou’s testimony: awakened by chemical-soaked cloth pressed on face, felt attacker’s cotton shirt and satin-smooth shorts, struggled, squeezed attacker’s organ, escaped.
• Security log: Baleros admitted at 1:30 A.M. in black Adidas shorts and fraternity T-shirt.
• Witnesses (Joseph, Montes, others): corroborated Baleros’s 1:30 A.M. arrival, attire, entry without proper authorization.
• Discovery in Room 310: gray bag containing black Adidas satin shorts, white fraternity T-shirt, chemical-stained handkerchief. Christian Alcala and Renato Alagadan positively identified these as Baleros’s.
• PNP laboratory report: handkerchief and Malou’s nightdress positive for chloroform.

Defense’s Evidence

• Petitioner’s alibi: attended fraternity party in Greenhills, dunked in pool, changed into barong and t-shirt at host’s house, returned to Celestial Marie only to sleep in Room 306; clothes and bag left earlier in Room 306.
• Fraternity brothers (Leonardo, Chan) and Montes confirmed his attire and movements.
• Forensic demonstration (Vargas): chloroform evaporates in 30 seconds without staining.
• Petitioner denied any sexual advances, presence of black shorts in bag, or intent to harm Malou.

Issue

Whether the CA erred in affirming RTC’s conviction for attempted rape based on circumstantial evidence and whether proof of the overt act of rape was sufficient.

Circumstantial Evidence and Positive Identification

– Direct eyewitness to assault absent; identity based on last-seen circumstances and physical evidence chain.
– Requirements under Rule 133, Sec. 4: multiple proven facts forming an unbroken chain leading to moral certainty.
– SC characterized identification of Baleros via attire, timing, and recovered garments as part of admissible circumstantial proof.

Overt Act Requirement for Attempted Rape

– Attempted rape demands commencement of carnal penetration (Art. 335, Art. 6 RPC).
– SC jurisprudence (People v. Lamahang; Perez v. CA; People v. Pancho): overt acts must be the d



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