Case Summary (G.R. No. L-16223-25)
Key Dates
• March 14, 2006 – Alleged incident of rape
• November 17, 2008 – RTC Branch 21, Manila judgment convicting accused of rape
• March 24, 2011 – Court of Appeals (CA) decision affirming conviction
• April 5, 2017 – Supreme Court decision setting aside the conviction
Applicable Law
• 1987 Philippine Constitution, Article III, Section 14(2) – Presumption of innocence; proof of guilt beyond reasonable doubt
• Revised Penal Code, Articles defining rape; Rules of Court, Rule 133, Section 2 (proof beyond reasonable doubt)
Facts of the Case
AAA received a text from the accused on the morning of March 14, 2006, inviting her to meet at Augusto San Francisco Street, Manila. They rode a jeepney to Rizal Avenue, shared a meal at Jollibee, then proceeded to Aroma Motel. AAA testified that she refused to ascend at first, was physically pulled upstairs, locked in a room, and forcibly raped despite her resistance and attempts to escape, including a call for help from inside the toilet. She later reported the incident to her cousin, who arranged a meeting to arrest the accused. Medico-legal examination disclosed fresh deep hymenal laceration, bleeding, a breast abrasion, and a hand contusion.
The defense claimed a consensual “lovers’ date”: that AAA and the accused were already in a romantic relationship, had mutually agreed to visit the motel, engaged in consensual intercourse which was halted at AAA’s request, and that the accused was unlawfully arrested. The accused’s mother testified that AAA had demanded money in exchange for her testimony.
RTC and CA Findings
The RTC found AAA’s testimony credible, accepted the presence of force and bodily harm, convicted the accused of rape, imposed reclusion perpetua, and awarded civil and moral damages. The CA affirmed, emphasizing the bruises and abrasions as evidence of force, and explaining AAA’s continued presence with the accused by her lack of knowledge of her way home.
Issue
Whether the prosecution established guilt for rape beyond reasonable doubt, or whether the possibility of consensual intercourse created reasonable doubt.
Supreme Court Ruling
The Supreme Court acquitted the accused on the ground of reasonable doubt. Although the trial courts found the complainant credible, the Supreme Court observed that the parties’ prior agreement to meet, travel, dine, and enter the motel together—without demonstrable resistance until the moment of intercourse—suggested possible consensuality. The bruises and abrasions could have resulted from voluntary acts during intercourse rather than forcible rape.
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Procedural History
- Accused was charged with rape under an information dated March 14, 2006 before RTC Branch 21, Manila.
- On November 17, 2008, the RTC found him guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and awarded civil and moral damages of ₱50,000.00 each.
- The Court of Appeals (CA), in CA-G.R. CR-H.C. No. 03702, affirmed the RTC decision on March 24, 2011.
- The Supreme Court, in G.R. No. 199894, promulgated its decision on April 5, 2017.
Facts of the Case
- AAA, a housemaid, received a text from the accused inviting her to meet on March 14, 2006.
- They met at Augusto San Francisco Street, Sta. Ana, Manila, and rode a jeepney to Rizal Avenue, Sta. Cruz.
- After sharing a meal at Jollibee, the accused suggested they talk and eat at Aroma Motel.
- At the motel, AAA allegedly tried to refuse and leave but was pulled upstairs, locked in a room, and forced onto a bed.
- AAA escaped momentarily to the restroom to call her cousin, PO3 Alberto German, but her phone died before she could give her exact location.
- The accused purportedly barged into the restroom, undressed her by force, and achieved carnal knowledge against her will.
- AAA suffered a deep hymenal laceration, an abrasion on her left breast, and a contusion on her right hand, as found by NBI medico-legal officer Dr. Wilfredo E. Tierra.
- After the incident, AAA and the accused rode the same jeepney back; upon reporting to German, a sting operation led to the accused’s arrest at a prearranged meeting.
Prosecution Evidence
- AAA’s eyewitness testimony detailing the sequence of events and non-consensual acts.
- Medico-legal findings of fresh hymenal laceration, bleeding edges, breast abrasion, and hand contusion.
- Officer German’s accoun