Title
People vs. Medel
Case
G.R. No. 123803
Decision Date
Feb 26, 1998
A pastor accused of rape was acquitted as the complainant's behavior post-incident and lack of corroborative evidence failed to prove guilt beyond reasonable doubt.

Case Summary (G.R. No. 123803)

Summary of Events

The prosecution contended that Medel forcibly engaged in sexual intercourse with Rula, while the defense posited that the act was consensual. They travelled to the provinces to resolve internal conflicts within their organization and returned to Baguio where they checked into Veny's Inn. After spending some time together, Medel reportedly initiated a conversation that suggested romantic interest, which culminated in alleged sexual assault.

Credibility of the Complainant

Rula vividly recounted the encounter, detailing how Medel forcibly restrained her, strangled her, and penetrated her against her will. Despite these claims, the court expressed apprehension regarding her credibility, citing her subsequent behavior, which seemed inconsistent with that of a typical sexual assault victim, such as not seeking help during the alleged attack or immediately after.

Reaction of the Complainant Post-Incident

Following the incident, Rula exhibited behavior that contradicted her claims of being raped. She engaged with Medel in social settings, visited his residence multiple times for vaccinations, and did not immediately disclose the assault to anyone. This raised suspicions regarding her testimony and led the court to question the sincerity of her accusations.

Examination of Evidence

The trial court convicted Medel primarily based on Rula's testimony, but the appellate court evaluated the evidence with scrutiny. It noted crucial inconsistencies in Rula's actions post-assault that did not align with someone who had experienced such trauma. The court highlighted the need for substantial corroborative evidence to support claims of rape, especially given the serious nature of the accusation and the lifelong consequences for the accused.

Legal Principles Applied

The court applied the principle of presumption of innocence, asserting that the prosecution bears the burden of proving the guilt of the accused beyond a reasonable doubt. It emphasized that a conviction should not rest solely on the testimony of the complainant without corroborating eviden

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