THE PEOPLE OF THE PHILIPPINES V.
RAYMUNDO RAPIZ Y CORREA
G.R.No. 240662, September 16, 2020
LAZARO-JAVIER, J.:
FACTS:
That on or about the 2nd day of April 2015, in the City of Las Pinas,
Philippines, and within the jurisdiction of this Honorable Court, the above-
named accused, with lewd design and by means of force, threat, and
intimidation and did then and there willfully, unlawfully and feloniously
have carnal knowledge with complainant AAA, against her will and consent.
The trial court found appellant guilty of the charges brought against
him. The trial judge noted that while the complainant could write her
name, she couldn't read. In Filipino, she could only count to ten (10) and
thirty (30) in English. She described how appellant sexually ravished her in
a truthful and accurate manner. He was able to unfairly coerce and
intimidate her into having sexual relations with him because of appellant's
moral authority over her as her mother's cousin. The contradictions in the
complainant's statement were signs that he was telling the truth. Dr.
Cornelio's medico-legal testimony on her sexual ravishment was
corroborated by her. The alleged inconsistency as to the actual time the
rape incident occurred, i.e., "April 2, 2015 at 4 o'clock in the afternoon"
was indicated in Police Senior Inspector Joylene Bulan's request for genital
examination, while "April 2, 2015 at 9:10 o'clock in the morning" was
indicated in Dr. Cornelio's medico-legal report——-Refers to a minor, if not
insignificant, detail. For rape does not include the element of time. When
compared to the complainant's positive and categorical testimony, the
appellant's denial is a poor defense. Furthermore, BBB's purported
animosity of appellant for allegedly refusing to lend her money is far too
weak a reason, nay, incentive, to falsely accuse appellant of rape.
ISSUE:
Did the Court of Appeals err in convicting appellant of rape?
RULING:
We acquit.
The conventional norm is that a victim's lone testimony in a rape
prosecution, if believable, is sufficient to support a conviction. The rationale
is that, due to the nature of the violation, the only evidence that can be
utilized to prove the accused's guilt is usually the testimony of the offended
party.
However, the accused's constitutional presumption of innocence
necessitates a moral certainty of his guilt beyond a reasonable doubt.
Furthermore, the prosecution's evidence must stand or fall on its own, and
it cannot be allowed to benefit from the defense's weaknesses. The
complainant's testimony must be analyzed with extreme caution, and she
must unavoidably be put on trial for her own credibility.