Title
Supreme Court
People vs. Garrido y Elorde
Case
G.R. No. 191258
Decision Date
Jul 8, 2015
Vincent Garrido was acquitted of rape charges due to inconsistencies in the victim's testimony, lack of corroborative evidence, and credible defense claims of consensual intercourse.

Case Summary (G.R. No. 201100)

Facts Before the RTC

Garrido was charged with the crime of rape, alleged to have occurred on October 21, 2004, in Las Piñas City. AAA, the 19-year-old victim, had gone out with the accused and others, eventually ending up at Garrido's house where the alleged rape took place. After consuming alcoholic beverages, AAA became intoxicated. Garrido, upon returning from the bathroom, turned off the lights and allegedly sexually assaulted AAA. The victim later reported the incident to her sister, revealing that she had previously been raped by Garrido.

Version of the Prosecution

AAA testified that, after being persuaded to stay at Garrido's house, she was sexually assaulted on multiple occasions while she was too intoxicated to effectively resist. The prosecution presented medical evidence from Dr. Bonnie Yap Chua, who noted physical marks and lacerations consistent with sexual assault.

Version of the Defense

The defense claimed that the sexual intercourse was consensual, arguing that AAA willingly stayed over after drinking and initiating contact with Garrido. Witnesses from the defense, including Garrido and his associates, corroborated his account of consensual encounters and claimed that AAA exhibited no signs of being raped.

The Ruling of the RTC

The RTC found Garrido guilty beyond reasonable doubt of rape, leading to a sentence of reclusion perpetua and financial penalties to AAA for civil indemnity and moral damages. The court favored the credibility of AAA's testimony, asserting that her intoxication did not inhibit her ability to recall the events clearly.

The Ruling of the Court of Appeals

The Court of Appeals upheld the RTC's ruling on October 20, 2009, but modified the amount of civil indemnity. The appellate court relied on the credibility of AAA's detailed account while dismissing the defense’s arguments as lacking sufficient merit.

Our Ruling

Upon reviewing the case, the Court reversed the decisions of the lower courts and acquitted Garrido due to reasonable doubt. The court identified inconsistencies in AAA's testimony regarding the events, including her recollections of being in the room with her companions. There were notable discrepancies about her level of intoxication and her responses during the alle

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