Case Summary (G.R. No. L-26370)
Key Dates
• February 10, 2009 – Alleged rape by Amarela
• February 11, 2009 – Alleged rape by Racho
• June 26, 2012 – RTC Joint Judgment convicting Amarela and Racho
• February 17, 2016 – CA Decision affirming RTC judgment
• January 17, 2018 – Supreme Court Decision reversing convictions
Applicable Law
• 1987 Constitution of the Republic of the Philippines (decision rendered 2018)
• Revised Penal Code, as amended by R.A. No. 8353 (Anti-Rape Law of 1997)
• Rules on standards of proof in criminal cases (beyond reasonable doubt) and assessment of witness credibility
Factual Background
[AAA] attended a community beauty contest near Maligatong Cooperative Building with her aunt. While attempting to use a restroom off to the side of the basketball-court venue, she was intercepted by Amarela, who forced her under an unfinished day-care stage, punched her abdomen and thigh, undressed both of them, then consummated sexual intercourse by force. She escaped, sought help from acquaintances, and was rerouted through several houses before reaching Racho’s home that same evening. There, instead of being delivered to her aunt, Racho allegedly forced her into a shanty along the way, punched her abdomen when she resisted, undressed and again raped her before leaving her to return home alone.
Procedural History
- Two Informations (Criminal Cases Nos. 64,964-09 and 64,965-09) for rape were jointly tried in RTC Branch 11, Davao City.
- On June 26, 2012, the RTC convicted both Amarela and Racho of rape beyond reasonable doubt and imposed reclusion perpetua plus civil indemnity and moral damages of ₱50,000 each.
- The appellants separately appealed to the Court of Appeals, which on February 17, 2016, affirmed the RTC in toto.
- The appellants elevated the case by petition for review on certiorari to the Supreme Court.
Issues on Appeal
• Whether the testimony of [AAA], standing alone, suffices to establish guilt beyond reasonable doubt, given alleged inconsistencies, poor lighting, physical improbabilities and inconclusive medical findings.
• Whether the Court of Appeals and RTC misapplied the “women’s honor” presumption and unduly favored the prosecution.
Supreme Court Ruling: Reversal and Acquittal
The Supreme Court reversed both the RTC and CA decisions and acquitted Amarela and Racho for the following reasons:
Credibility Assessment and “Women’s Honor” Doctrine
• The outdated presumption that Filipina victims will not lie about sexual assault (“women’s honor” doctrine) no longer reflects social realities and may produce unfair convictions.
• A complainant’s testimony, even if uncontradicted, must be credible, consistent with human experience, and free from material inconsistencies.Inconsistencies between Affidavit-Complaint and Trial Testimony
• [AAA] gave divergent accounts of where and how she was accosted by Amarela—first stating she was pulled from the stage area, and later testifying she was intercepted en route to the restroom.
• Such variance undermines her claim of forcible abduction and casts doubt on whether the assault occurred as described.Identification under Poor Lighting Conditions
• [AAA] admitted the path to the day-care stage was dark and tree-covered, rendering facial identification of Amarela implausible.
• Positive identification is the prosecution’s burden; unexplained contradictions in how the victim could identify her assailant erode the reliability of her testimony.Physical Improbabilities of the Assault Scenario
• The claim that two people were undressed and forced to engage in intercourse under a makeshift stage only two feet high strains credulity and departs from ordinary experience of physical space and human resistance.Medical Examination Findings
• The medico-legal report noted only two hymenal lacerations (3 o’clock and 9 o’clock positions) with no external contusions or bruises on thighs or abdomen.
• Scien
Case Syllabus (G.R. No. L-26370)
Case Background
- Appeal from the 17 February 2016 Decision of the Court of Appeals (CA-G.R. CR HC Nos. 01226-MIN & 01227-MIN) affirming the 26 June 2012 Joint Judgment of the Regional Trial Court (RTC), Branch 11, Davao City.
- Accused-appellants: Juvy D. Amarela and Junard G. Racho.
- Charged with rape under Articles 266-A and 266-C, RPC as amended by RA 8353.
Criminal Informations
- Case No. 64,964-09 (February 10, 2009): Accused forcibly had carnal knowledge of [AAA] against her will after boxing her legs.
- Case No. 64,965-09 (February 11, 2009): Accused forcibly had carnal knowledge of [AAA] against her will after grappling her.
- Jointly tried; appeals consolidated by the CA on 13 November 2015.
Prosecution’s Version of Facts
- Victim [AAA], a housekeeper, attended a beauty contest in Calinan, Davao City.
- First Incident (Amarela):
• On her way to a comfort room behind the cooperative, Amarela pulled her toward a day care center, punched her abdomen, undressed her, boxed her thigh, placed himself on top of her, and raped her.
• She shouted; three men intervened; Amarela fled. She hid, then returned home and later reported the assault. - Second Incident (Racho):
• Brought by Racho under duress to a shanty instead of her aunt’s house; after boxing her abdomen and despite resistance (kicking), he undressed them both, placed himself on top, and raped her.
• He left; victim went home alone, cried, then reported the matter to family and police. - Medical Exam (12 Feb 2009): No external injuries except erythematous perihymenal area and complete hymenal lacerations at 9 and 3 o’clock; internal/speculum/anal exams as noted.
Defense Evidence
- Amarela’s Testimony: Denied involvement; claimed heavy drinking, a blackout, and no memory of events after February