Criminal Case Digest: PEOPLE VS VICENTE

PEOPLE VS VICENTE

Criminal Case Digest

Digested Cases

Criminal Law 

The accused-appellant, Vicente R. Miñano, was charged with the crime of rape in Criminal Case No. 1673 before the Regional Trial Court, Branch 81, Fourth Judicial Region, Romblon, Romblon.

Upon arraignment, the accused-appellant entered the plea of not guilty. Thereafter, trial on the merits ensued. On January 21, 1991, the trial court render its decided that the accused VICENTE R. MIÑANO GUILTY is beyond reasonable doubt of the crime of Rape.

In this appeal, the accused-appellant assails his conviction by the trial court. It allegedly failed to take into account the following: 1) several inconsistencies in the testimony of the victim; 2) delay in filing the complaint; 3) admission of the victim that she was menstruating when the rape incident happened; and 4) affidavit of waiver and desistance which was executed by the victim.


ISSUE: WON THE ACCUSED IS GUILTY BEYOND REASONABLE DOUBT


HELD:
Although this Court ordinarily relies on the factual findings of the trial court, recognizing its superior competence to assess the credibility of the witnesses through direct observation of their deportment on the stand, We decline to apply this policy in the case before Us. ¹⁴ It is not enough that the victim expressed her emotions to the fullest while testifying, the totality of the evidence should be considered before reaching the conclusion that, indeed, her testimony is credible and positive. A meticulous examination of the records and analysis of the arguments of the parties enabled Us to unearth the truth behind the victim's serious charge of rape against the accused-appellant. The prosecution has not sufficiently established his guilt to the point of overcoming the constitutional presumption of innocence that he enjoys.
The accused-appellant sets up the main defenses that at the time of the rape incident, their entire family was at home and the victim left their house on March 11, 1988. Although these were adequately corroborated by his wife, not much credence should be given to her testimony. It is undeniably tainted with bias since it springs from the natural desire of a wife to bail out her husband from criminal liability even to the extent of lying . ⁴² We thus find his defenses weak. However, it is an enduring rule that the prosecution must rely on the strength of its evidence rather than on the weakness of that of the defense. ⁴³ This Court has no option but to declare that the prosecution has failed to meet the exacting test of moral certainty and proof of guilt of the accused-appellant beyond reasonable doubt. It is imperative that We reverse the trial court's guilty verdict.
WHEREFORE, the decision appealed from is hereby REVERSED. The accused-appellant is ACQUITTED of the crime of rape.
SO ORDERED.