Case Summary (G.R. No. 199894)
Key Dates and Applicable Law
Relevant dates include the alleged offense date (March 14, 2006), trial court judgment (November 17, 2008), Court of Appeals decision (March 24, 2011), and Supreme Court resolution (decision date falls after 1990, so the 1987 Philippine Constitution supplies the constitutional framework cited in the decision). Applicable legal standards invoked include the presumption of innocence guaranteed by the Constitution, the requirement of proof beyond reasonable doubt (due process protection), and Section 2, Rule 133 of the Rules of Court on the degree of proof required in criminal cases. Confidentiality of the victim’s identity was observed pursuant to RA No. 9262.
Charge and Information
The information charged the accused with rape, alleging that on or about March 14, 2006, in Manila, the accused willfully, unlawfully and feloniously, by force, violence, intimidation and fraudulent machination, had carnal knowledge of AAA. The information described a sequence: text message invitation, meeting at Augusto San Francisco Street, travel to Rizal Avenue, eating at Jollibee, entry to Aroma Motel under a pretext, an encounter in a locked motel room culminating in forcible sexual intercourse against the complainant’s will and consent.
Prosecution Evidence
AAA testified that she received a text from the accused and met him at 9:00 a.m. They rode a jeepney to Rizal Avenue, ate at Jollibee, then proceeded to Aroma Motel. She said the accused pulled her by the hand up the stairs, they were ushered into a room, she tried to leave but the accused locked the door and pushed her onto the bed. She attempted to hide in the toilet and called a cousin who was a police officer, but her phone failed. The accused allegedly forced entry into the toilet, pulled her back to the bed, undressed her, went on top of her and forcibly inserted his penis into her vagina despite her resistance. Afterward she dressed and left. She later arranged, at her cousin’s direction, a meeting where the cousin apprehended the accused. The NBI medico‑legal officer reported fresh deep hymenal laceration with bleeding, an abrasion on the left breast, and contusion on the right hand.
Defense Evidence
The accused denied rape and asserted a consensual lovers’ relationship with AAA beginning January 6, 2006, with a romantic relationship thereafter. He testified they agreed to a date on March 14; they rode together, ate at Jollibee, agreed to go to a motel, entered a room that could be locked from the inside, and engaged in sexual relations after mutual acts of undressing and kissing. He said that he stopped when she told him she was not yet ready, they dressed and departed together, and later he was arrested after being lured to a meeting by AAA’s cousin. The accused’s mother testified that AAA was already her son’s girlfriend, recounted a conversation in which the cousin allegedly solicited P200,000, and claimed AAA refused to speak to her about the incident.
RTC Ruling
The Regional Trial Court found the accused guilty beyond reasonable doubt of rape, sentenced him to reclusion perpetua, and awarded civil indemnity and moral damages of P50,000.00 each to the victim. The RTC credited the accused’s period of detention as service of sentence.
Court of Appeals Ruling
On appeal the Court of Appeals affirmed the conviction. The CA accepted AAA’s testimony as credible, found that bruises and abrasions established bodily harm consistent with force used to accomplish carnal knowledge, and explained the parties’ post‑incident journey home by AAA’s inability to find her way back. The CA denied the accused’s appeal and affirmed the RTC decision.
Issue Presented to the Supreme Court
Whether the RTC and the Court of Appeals correctly found and pronounced the accused guilty of rape beyond reasonable doubt, given the conflicting accounts of consensual sex versus forcible rape, the surrounding circumstances, and the medico‑legal findings.
Supreme Court Ruling — Outcome
The Supreme Court reversed and set aside the lower courts’ decisions, acquitted Carlito Claro y Mahinay for failure of the prosecution to prove guilt beyond reasonable doubt, ordered his immediate release unless other lawful causes justified continued confinement, and directed the Bureau of Corrections to implement his release and report compliance.
Supreme Court Reasoning — Overview
The Court recognized the deference usually accorded to trial court findings on witness credibility and the CA’s affirmance of those findings. Nonetheless, the Court found that the totality of circumstances left reasonable doubt as to whether the sexual intercourse was consensual. The Court emphasized that the accused and the complainant were adults, that many details in both versions showed prior agreement to meet and travel together, and that the parties entered the motel together without demonstrable or sustained resistance. The Court found that physical markings (abrasions and contusions) observed in the medico‑legal examination did not conclusively prove that force was employed to overcome the complainant’s will; such injuries could also occur during consensual sexual activity. The Court held that the presence of such injuries did not justify rejecting consensuality as a reasonable possibility.
Supreme Court Reasoning — Legal Standards Employed
The decision applied the constitutional presumption of innocence and the due‑process requirement that the prosecution establish guilt beyond reasonable doubt (a standard the Court linked to the protections of the 1987 Constitution). The Court reiterated settled principles: (1) the prosecution bears the burden of proving every element of the offense and the accused’s participation; (2) factual findings of trial courts are generally respected, but appellate courts must still ensure the prosecution has met its burden; (3) reasonable doubt is not a mere possible or speculative doubt but is the state of the case after comparison and consideration of all evidence that precludes an abiding conviction to a moral certainty. The Court cited Section 2, Rule 133 of the Rules of Court regarding the degree of proof required.
Application of the Reasonable Doubt Standard
Balancing the prosecution and defense evidence, the Court found that the prosecution failed to exclude reasonable hypotheses consistent with innocence — namely, that the sexual encounter was consensual. The Court stressed that suspicion, even strong, is insufficient; the prosecution must produce evidence that convi
...continue readingCase Syllabus (G.R. No. 199894)
Case Caption, Citation and Procedural Posture
- Reported at 808 Phil. 455, Third Division, G.R. No. 199894, April 05, 2017.
- Plaintiff-Appellee: People of the Philippines; Accused-Appellant: Carlito Claro y Mahinay.
- The judgment under review: Decision of the Court of Appeals (CA) promulgated March 24, 2011 in CA-G.R. CR-H.C. No. 03702, which affirmed the Regional Trial Court (RTC), Branch 21, Manila judgment dated November 17, 2008 convicting the accused of rape.
- The Supreme Court (penner: Justice Bersamin) issued the final decision reversing the CA and RTC and acquitting the accused for failure to prove guilt beyond reasonable doubt.
The Charge / Information
- Accused charged with rape for acts alleged to have occurred on or about March 14, 2006, in the City of Manila.
- Allegations in the information:
- That the accused willfully, unlawfully and feloniously, with lewd designs and by means of force, violence and intimidation, and fraudulent machination, had carnal knowledge of AAA.
- Mode and means alleged: texting to arrange meeting at the corner of Augusto Francisco Street; inviting her for a stroll at Rizal Avenue; ordering food from Jollibee; bringing her to Aroma Motel under the pretext they would talk and eat; entering and locking a room; pulling her onto the bed, kissing, undressing her and inserting his penis into her vagina against her will and consent.
- Complaint caption and real names: victim and immediate family names withheld pursuant to RA No. 9262; fictitious names used (AAA).
Facts as Presented by the Prosecution
- Sequence of events as testified by AAA:
- Around 9:00 a.m., March 14, 2006, AAA, a housemaid, received a text from the accused asking to meet. The accused was a security guard near her workplace.
- They met on Augusto San Francisco Street, Sta. Ana, Manila, boarded a passenger jeepney bound for Rizal Avenue, Sta. Cruz, Manila.
- They entered a Jollibee on Rizal Avenue and ordered food.
- They later went to a nearby house identified as Aroma Motel. AAA refused to go up the stairs; the accused held her by the hand and pulled her upstairs, insisting they would only talk and eat.
- A male attendant ushered them into a room. Upon entering, AAA tried to leave; the accused closed the door and pushed her toward the bed. She attempted to leave but the door was locked.
- The accused pulled her back to the bed, told her he loved her; she said she needed to go to the toilet and called her cousin, Alberto German (a police officer), but her phone ran out of charge before she could give her location.
- The accused barged into the toilet, pulled her back to the bed, forcefully undressed her completely, went on top of her and forcibly inserted his penis into her vagina. She punched to stop him but could not prevent the act.
- After the act, she dressed and left the room but rode with him in the same passenger jeepney as she did not know her way back.
- Upon arriving home, she reported to her cousin German, who instructed her to contact the accused and arrange a meeting to apprehend him. At the meeting, German, identifying himself as a police officer, seized the accused; the accused tried to run but was brought to the NBI for investigation.
- Medico-legal examination by Dr. Wilfredo E. Tierra (NBI medico-legal officer) on March 14, 2006:
- Presence of fresh deep hymenal laceration at 5 o'clock position with edges bleeding.
- Abrasion measuring 1.3 cm on the left breast.
- Contusion measuring 1.5 cm on the right hand.
Facts as Presented by the Defense
- Accused’s testimony and version:
- He and AAA first met on January 6, 2006; they became friends and, after two months, lovers.
- They had a prior date on March 6, 2006 and agreed to meet again on March 14, 2006.
- On March 14 they met at Augusto San Francisco Street, boarded a passenger jeepney to Jollibee on Rizal Avenue; at Jollibee he ordered food and asked if they would go to a motel, and AAA assented.
- They walked together to Aroma Motel; a room boy led them to a room with a doorknob lockable from inside.
- Once inside, AAA went to the restroom and later came out wearing only a towel; she told him she loved him, they kissed, she removed the towel and he undressed; she did not resist when he went on top and inserted his penis in her vagina; he stopped when she said she was not yet ready.
- They then dressed, left the motel together, boarded a passenger jeepney, parted ways; she later called and asked to meet again; at the meeting a police officer (German) arrested and handcuffed him.
- Testimony of the accused’s mother:
- Asserted AAA was already her son's girlfriend prior to the incident.
- Upon visiting the police headquarters after learning of the arrest, she saw AAA who referred her to talk to German.
- She recounted German allegedly saying to her in Tagalog: "Wala nang madami pang usapan, basta mangako ka sa akin na magbibigay ka ng P200,000.00" (no long talk, just promise me you will give P200,000).
- She asked AAA what really happened; AAA refused to answer.
Ruling of the Regional Trial Court (RTC)
- RTC (Branch 21, Manila; presiding judge penner: Judge Amor A. Reyes) found the accused guilty beyond reasonable doubt of rape.
- Sentence imposed:
- Reclusion perpetua.
- Ordered to pay AAA P50,000.00 as civil indemnity and P50,000.00 as moral damages.
- Costs imposed.
- Period of