Rape conviction; victim's testimony; inconsistencies
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.[1] In People v. Patentes,[2] 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.
The testimony of the
offended party in crimes against chastity should not be received with
precipitate credulity for the charge can easily be concocted.[3] Courts
should be wary of giving undue credibility to a claim of rape, especially
where the sole evidence comes from an alleged victim whose charge is not
corroborated and whose conduct during and after the rape is open to
conflicting interpretations.[4] While judges ought to be cognizant of
the anguish and humiliation that a rape victim undergoes as she seeks justice,
they should equally bear in mind that their responsibility is to render
justice based on the law.[5]
The numerous inconsistencies in the testimony of private complainant may create reasonable doubt. In view of the foregoing considerations, the presumption of innocence in favor of appellant must be upheld considering that the evidence brought forth in trial falls short of the quantum of proof to support a conviction.[6]
The testimony of the
offended party in crimes against chastity should not be received with
precipitate credulity for the charge can easily be concocted.[3] Courts
should be wary of giving undue credibility to a claim of rape, especially
where the sole evidence comes from an alleged victim whose charge is not
corroborated and whose conduct during and after the rape is open to
conflicting interpretations.[4] While judges ought to be cognizant of
the anguish and humiliation that a rape victim undergoes as she seeks justice,
they should equally bear in mind that their responsibility is to render
justice based on the law.[5]The numerous inconsistencies in the testimony of private complainant may create reasonable doubt. In view of the foregoing considerations, the presumption of innocence in favor of appellant must be upheld considering that the evidence brought forth in trial falls short of the quantum of proof to support a conviction.[6]
[1] Section 2, Rule 133, Revised Rules on Evidence; People v. Palma Gil, 348 Phil. 608, 626 (1998).
[2] https://www.projectjurisprudence.com/2021/08/gr-no-190178-february-12-2014.html.
[3] People v. Gilbero, 425 Phil. 241, 249 (2002).
[4] People v. Medel, 350 Phil. 208, 226 (1998).
[5] People v. Alvario, 341 Phil. 526, 538-539 (1997).
[6] People v. Villaflores, 422 Phil. 776, 792 (2001), citing People v. Bravo, 376 Phil. 931, 944 (1999).