Criminal Law

People v. Claro G.R. No. 199894 April 5, 2017 Reasonable Doubt, Accused Acquitted on the ground of Reasonable Doubt

FACTS:

AAA, a housemaid, was invited by accused Carlito Claro who was then working as a security guard near AAA’s place of work, to meet at Augusto San Francisco Street, Sta. Ana Manila. There, they proceeded on board a passenger jeepney to the Jollibee restaurant in Rizal Avenue.

Thereafter, they proceeded to Aroma Motel. Upon entering a room at the motel, AAA allegedly tried to leave, but the accused closed the door and pushed her towards the bed. She still attempted to leave but the door was locked. He pulled her back to the bed, telling her that he loved her. Instead of responding to him, she said that she needed to go to the toilet. Once inside the toilet, she called her cousin, Alberto German (German), a police officer, but she was unable to give him her exact location after her phone ran out of charge. 

The accused barged inside the toilet and again pulled her back to the bed. He forcefully undressed her completely, went on top of her, and forcibly inserted his penis inside her vagina. She kept on punching to try to stop him, but to no avail. After he was done, she immediately put on her clothes and left the room. But she was compelled to ride with him in the same passenger jeepney because she did not know her way back.

Upon arriving home, she promptly reported the incident to German, who instructed her to contact the accused and agree to meet with him again so that they could apprehend him.

The accused denied the accusation.

In his defense, he claimed that he and AAA were lovers, and the sexual intercourse between them was consensual.

Likewise, the mother of the accused asserted that AAA was already her son’s girlfriend prior to the incident.

The RTC found the accused guilty beyond reasonable doubt of rape.

On appeal, the CA affirmed the conviction.

ISSUE:

Whether or not R TC and the CA correctly find and pronounce the accused guilty of rape beyond reasonable doubt.

RULING:

The Court acquits the accused on the ground of reasonable doubt.

It is noticeable that the versions of AAA and the accused ultimately contradicted each other on whether rape or consensual sex had transpired between them. Their contradictions notwithstanding, the circumstances – whether based on her recollection or on his – indicated that she had willingly met with him in order to go on a lovers’ date. Their meeting on Augusto San Francisco Street, and their going together by jeepney to Rizal Avenue, where they entered the Jollibee restaurant to share the meal were undoubtedly by their prior agreement. It was while they were in the restaurant when they discussed checking in at the Aroma Motel, but once she assented to their checking in the Aroma motel, they walked together towards the motel, and entered together.

Although she claimed that he had held her by the hand and pulled her upstairs, there is no evidence showing that she resisted in that whole time, or exhibited a reluctance to enter the motel with him. Instead, she appeared to have walked with him towards the motel, and to have entered it without hesitation. What she did not do was eloquent proof of her consent.

In every criminal case, the accused is entitled to acquittal unless his guilt is shown beyond reasonable doubt. Proof beyond reasonable doubt does not mean such a degree of proof as, excluding possibility of error, produces absolute certainty. Only moral certainty is required, or that degree of proof which produces conviction in an unprejudiced mind.

Requiring proof of guilt beyond reasonable doubt necessarily means that mere suspicion of the guilt of the accused, no matter how strong, should not sway judgment against him. It further means that the courts should duly consider every evidence favoring him, and that in the process the courts should persistently insist that accusation is not synonymous with guilt; hence, every circumstance favoring his innocence should be fully taken into account.

Without the proof of his guilt being beyond reasonable doubt, therefore, the presumption of innocence in favor of the accused herein was not overcome. His acquittal should follow.

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