Rape Cases Doctrines

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Rape cases accused acquitted:

 Inconsistencies
1. It is inherent in the crime of rape that the conviction of an accused invariably depends upon
the credibility of the victim as she is oftentimes the sole witness to the dastardly act. Thus,
the rule is that when a woman claims that she has been raped, she says in effect all that is
necessary to show that rape has been committed and that if her testimony meets the
crucible test of credibility, the accused may be convicted on the basis thereof.[29]However,
the courts are not bound to treat the testimony of the victim as gospel truth. Judges are
duty-bound to subject her testimony to the most rigid and careful scrutiny lest vital details
which could affect the outcome of the case be overlooked or cast aside.

WHEREFORE, premises considered, the Decision of the Court of Appeals dated 16


November 2005 in CA-G.R. CR-H.C. No. 01332, affirming the decision of the Regional Trial
Court of Pasig City, Branch 166 in Criminal Case No. 124878-H, is hereby REVERSED and SET
ASIDE; appellant is ACQUITTED on ground of reasonable doubt. The Director of the Bureau
of Corrections is hereby directed to cause the immediate release of appellant, unless the
latter is being lawfully detained for another cause; and to inform the Court of the date of his
release, or the reasons for his continued confinement, within ten days from notice. No
costs.

- PP vs Rudy Salaga y Quitanio G.R. No. 172323 January 29, 2007

2. All in all, the prosecutions evidence is hazy and contradictory sorely lacking as it is in
material details. Admittedly, a conviction can be based on circumstantial evidence. In the
present case, however, the chain of circumstances does not show a coherent and consistent
story that would give rise to a certitude sufficient to convince this Court to impose on
appellant the very grave penalty of reclusion perpetua. His own defense is admittedly
weak. But conviction is never founded on the weakness of the defense. Rather, it always
rests on the strength of the prosecutions evidence.
- PP. Vs. Loven Daganta G.R. No. 122339. August 4, 1999

 Easy to fabricate difficult to prove


3. In rape cases, the prosecution bears the primary duty to present its case with clarity and
persuasion, to the end that conviction becomes the only logical and inevitable
conclusion. The Constitution requires moral certainty or proof beyond reasonable doubt; a
conviction cannot be made to rest on possibilities.

-PP vs Ignacio Poras G.R. No. 177747 February 16, 2010

4. In the case before us, the pieces of circumstantial evidence do not indubitably lead to the
conclusion that appellant is guilty of the crime charged. When two antithetical
interpretations may be inferred from the circumstantial evidence presented, the situation
calls for the application of the equipoise rule i.e., when the evidence is consistent with a
finding of innocence and also compatible with a finding of guilt, then the evidence is at
equipoise and does not fulfill the test of moral certainty sufficient to support a conviction.
- People v. Masalihit 360 Phil. 332, 342, December 14, 1991

5. A conviction cannot be made to rest on imagination. The Constitution requires moral


certainty or proof beyond reasonable doubt. The scant evidence on record cannot justify a
leap to the conclusion that the abuse appellant perpetrated on Leah amounted to carnal
knowledge under any of the three circumstances specified in Article 335 of the Revised
Penal Code.

WHEREFORE, the appeal is GRANTED and the assailed Decision is


hereby REVERSED and SET ASIDE. Appellant Florentino Quijano Sr. is ACQUITTED on
reasonable doubt.

- PP vs Florentino Quijano Sr. G.R. Nos. 144523-26. June 10, 2003

6. In reviewing rape cases, the Court is guided by these principles: First, the prosecution has to
show the guilt of the accused by proof beyond reasonable doubt or that degree of proof
that, to an unprejudiced mind, produces conviction. Second, unless there are special
reasons, the findings of trial courts, especially regarding the credibility of witnesses, are
entitled to great respect and will not be disturbed on appeal. Third, the disposition of rape
cases are governed by the following guidelines: (1) an accusation for rape can be made with
facility; it is difficult to prove but more difficult for the person accused, though innocent, to
disprove; (2) in view of the intrinsic nature of the crime of rape where only two persons are
usually involved, the testimony of the complainant must be scrutinized with extreme
caution, and (3) the evidence for the prosecution must stand or fall on its own merits and
cannot draw strength from the weakness of the evidence of his defense.
- PP vs Bidoc G.R. No. 169430 October 31, 2006

7. The credibility of the victim is, in rape cases, almost always the single most important
issue.[38] If her testimony passes the test of credibility, which means it is credible, natural,
convincing, and consistent with human nature and the normal course of things, the accused
may be convicted solely on the basis thereof.[39] If the prosecution, however, fails to
discharge the onus of proving the guilt beyond reasonable doubt of the accused, even if his
defense is weak, he has the right to be freed. More than that, it is the Courts constitutional
duty to acquit him.

WHEREFORE, the Decision of the Court of Appeals in CA-G.R. CRHC No. 00287 is REVERSED
and SET ASIDE. Appellant, Daniel Perez y Bacani, is ACQUITTED of rape in Criminal Case No.
98-14590 of the Regional Trial Court of Antipolo City

- Pp vs Daniel Perez y Bacani G.R. No. 172875 August 15, 2007

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