People vs. Sayana (405 SCRA 203)

28 Jul


Appellant was charged with two counts of rape committed against the daughter of his common-law wife. The prosecution evidence showed that appellant forced himself upon the daughter of his eleven-year old common-law wife in their residence in Bulacan. Appellant swore that he treated the complainant as his own child and he did not have the heart to molest her. Appellant’s alibi was corroborated by his father, and their neighbor, and also by his time card, as against the allegations. Several medical examinations were conducted by different physicians with some contradictory results. It was also observed that complainant’s narration of how appellant allegedly ravished her on two occasions (of rape) were incredibly identical, as if lifted from a single script.


Whether or not the appellant is entitled for acquittal.


YES. Appellant was acquitted.


The explanation given by the physician who testified for the prosecution itself, plus the fact that complainant underwent several gynecological examinations before she went to the authorities discount the credibility of the latter’s testimony that she has been raped.

In rape cases, it is the primordial duty of the prosecution to present its case with clarity and persuasion to the end that conviction becomes the only logical and inevitable conclusion. Proof beyond reasonable doubt is required. Although the law does not demand absolute certainty of guilt, it nonetheless requires moral certainty to support a judgment of conviction. Where the inculpatory facts admit of several interpretations, one consistent with accused’s innocence and another with his guilt, the evidence thus adduced fails to meet the test of moral certainty and it becomes the constitutional duty of the Court to acquit the accused (doctrine of pro reo).

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Posted by on July 28, 2012 in Case Digests, Criminal Law


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