People of the Philippines vs. Felimon Patentes y Zamora

G.R. No. 190178, February 12, 2014

Patentes was charged with forcible abduction with rape and 7 counts of rape. During trial, AAA, the complainant testified that she was threatened and brought to the accused’s residence where she was raped for 8 days. She claims to have been mauled, boxed, slapped, tied, and dragged, and only managed to escape after her agreement that she will marry Patentes. They arranged the marriage with AAA’s mother but due to latter’s disapproval and surprise to the fast-paced events, she talked to AAA and there she learned about AAA’s ordeal.

Patentes argued that he accompanied AAA to bring medicines to her grandmother. Patentes offered to bring AAA to her house but AAA refused and insisted that she wanted to live with AAA because she’s fed up with her mother calling her ‘buntog’ or prostitute. She stayed with AAA together with his family. She slept in the same room with Patentes and she was freely roaming the house. That the AAA’s grandfather even visited 2 days after their living together and AAA’s mother’s disapproved of the marriage because of Patente’s social standing.

ISSUE: Whether or not a person accused of rape may be convicted based solely on the testimony of victim who positively identified him to be the perpetrator notwithstanding blatant inconsistencies therein.

In reviewing rape cases, the Court is guided by the following principles: (1) to accuse a man of rape is easy, but to disprove the accusation is difficult, though the accused may be innocent; (2) inasmuch as only two persons are usually involved in the crime of rape, the testimony of the complainant should be scrutinized with great caution; and (3) the evidence for the prosecution must stand or fall on its own merit and should not be allowed to draw strength from the weakness of the evidence for the defense. So long as the private complainant’s testimony meets the test of credibility, the accused may be convicted on the basis thereof.

The time-honored test in determining the value of the testimony of a witness is its compatibility with human knowledge, observation and common experience of man. Thus, whatever is repugnant to the standards of human knowledge, observation and experience becomes incredible and must lie outside judicial cognizance. The following inconsistencies in complainant’s testimony is found to be incompatible to human experience:
(1) the admission that she during her abduction she was brought to accused’s house where 8 family members of the latter also resides;
(2) that she was not able to ask for help from any of the family member nor any of them was able to realize that accused was keeping her against her will;
(3) the discussion of wedding plans with her friend after her ordeal;
(4) admission that she was able to visit her grandmother within the period of the alleged abduction when she was supposed to be kept inside accused’s house against her will; and
(5) lastly, that she was repeated mauled by accused on their way to his to residence and within the duration of abduction but no physical injuries was seen during the medical examination conducted after the incident. A conviction in a criminal case must be supported by proof beyond reasonable doubt, which means a moral certainty that the accused is guilty; the burden of proof rests upon the prosecution. In the case at bar, the prosecution has failed to discharge its burden of establishing with moral certainty the truthfulness of the charge that appellant had carnal knowledge of AAA against her will using threats, force or intimidation.

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