The Supreme Court acquitted Pacifico Sangcajo, Jr. of rape, reversing the lower courts’ conviction due to reasonable doubt. The Court found the complainant’s testimony to be improbable, particularly regarding the physical mechanics of the alleged assault. This decision underscores the principle that a conviction requires proof beyond a reasonable doubt, and that doubts arising from the evidence, or lack thereof, must be resolved in favor of the accused. This ruling highlights the importance of scrutinizing testimonies in sexual assault cases, ensuring that convictions are based on credible and logically consistent evidence.

When Improbability Undermines Justice: A Rape Case Under Scrutiny

This case revolves around an accusation of rape brought by AAA against Pacifico Sangcajo, Jr., her mother’s cousin. The alleged incident occurred after a drinking session at Pacifico’s residence, where AAA was temporarily staying. AAA claimed that after consuming two large bottles of beer, she became dizzy and fell asleep on Pacifico’s “papag” (wooden bed). She testified that she awoke to Pacifico on top of her, forcibly removing her undergarments and penetrating her despite her attempts to resist. Pacifico, however, maintained that the sexual intercourse was consensual.

The Regional Trial Court (RTC) initially convicted Pacifico, finding AAA’s testimony credible. The Court of Appeals (CA) affirmed this conviction, further awarding moral and exemplary damages to AAA. However, the Supreme Court took a different view, acquitting Pacifico based on reasonable doubt. The Court emphasized that in sexual abuse cases, the testimony of the complainant must be scrutinized with great caution, and the prosecution’s evidence must stand on its own merits, without relying on the weakness of the defense. The Court outlined crucial guidelines for deciding such cases, including the understanding that rape accusations can be easily made but are difficult to disprove, and that the evidence must be carefully evaluated.

The Supreme Court’s decision hinged on the improbability of AAA’s account of the assault. AAA testified that Pacifico held both her hands down with his hands and pinned her legs down with his thighs, all while simultaneously removing her shorts and undergarments, spreading her legs, and penetrating her. The Court found this sequence of events physically implausible. As the Court articulated,

“Evidence, to be believed, must not only proceed from the mouth of a credible witness, but it must be credible in itself – such as the common experience and observation of mankind can approve as probable under the circumstances. We have no test of the truth of human testimony, except its conformity to our knowledge, observation, and experience. Whatever is repugnant to these belongs to the miraculous and is outside of judicial cognizance.”

This principle underscores the importance of aligning testimonies with logical possibility and common human experience.

Further undermining AAA’s account was the lack of physical evidence corroborating her claim of force. The medico-legal report did not mention any injuries to her hands or other parts of her body, and she provided no clear evidence of resistance beyond her assertion. The Court also noted the absence of any indication that AAA’s level of intoxication rendered her incapable of resisting Pacifico’s advances. These factors collectively contributed to the Court’s doubt regarding the veracity of her allegations. The law did not require the victim to prove the degree of resistance in relation to the force applied, the allegation of force in the case could be open to doubt, considering that it did not jibe with human experience or no physical evidence was presented to substantiate it.

The Court also addressed the lower courts’ rejection of Pacifico’s defense of consensual sexual intercourse. The Court noted that the absence of “independent” evidence of a romantic relationship, such as letters or mementos, was an unreasonable basis for dismissing his defense. Consensual sexual intercourse does not always require a romantic relationship; it can also arise from mutual attraction or lust. The Court further emphasized that AAA’s conduct prior to the intercourse, including drinking with Pacifico and seeking permission to sleep on his “papag,” suggested a level of comfort and willingness that supported the possibility of consent. Given that they had been drinking Red Horse Grande, a strong beer, the woman surely knew that her discernment would soon be affected.

The Supreme Court reaffirmed the presumption of innocence, emphasizing that it is the State’s responsibility to prove guilt beyond a reasonable doubt. The Court cautioned against relying solely on the victim’s testimony without considering other evidence and the overall plausibility of the account. As highlighted in People v. Domogoy, G.R. No. 116738, March 22, 1999, 305 SCRA 75, 89-92, “The mere invocation of the traditional and proverbial modesty of the Filipina does not prevail over or dispense with the need to present proof sufficient to overcome the constitutional presumption of innocence.” This underscores the importance of balancing empathy for victims of sexual assault with the constitutional rights of the accused.

The Court also quoted United States v. Youthsey, 91 Fed. Rep. 864, 868, defining reasonable doubt as

“a doubt growing reasonably out of evidence or the lack of it. It is not a captious doubt; not a doubt engendered merely by sympathy for the unfortunate position of the defendant, or a dislike to accept the responsibility of convicting a fellow man.”

Based on this principle, the Supreme Court concluded that the prosecution failed to establish Pacifico’s guilt beyond a reasonable doubt, leading to his acquittal.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to prove Pacifico Sangcajo, Jr.’s guilt of rape beyond a reasonable doubt, considering the inconsistencies and improbabilities in the complainant’s testimony.
Why did the Supreme Court acquit the accused?	The Supreme Court acquitted Pacifico because it found the complainant’s testimony regarding the alleged assault to be physically improbable and inconsistent, creating reasonable doubt about his guilt. The Court also emphasized the lack of corroborating physical evidence and the possibility of consensual sexual intercourse.
What is the significance of ‘reasonable doubt’ in this case?	Reasonable doubt means that based on the evidence presented, or lack thereof, there is a logical reason to doubt the accused’s guilt. The prosecution must overcome the presumption of innocence by proving every element of the crime beyond this reasonable doubt.
What were the improbabilities in the complainant’s testimony?	The improbabilities included the complainant’s claim that Pacifico simultaneously held both her hands and pinned her legs while removing her undergarments and penetrating her, which the Court found physically implausible.
Did the lack of physical injuries affect the Court’s decision?	Yes, the absence of physical injuries to the complainant’s hands or other parts of her body, which would have supported her claim of force, contributed to the Court’s doubt regarding the veracity of her allegations.
How did the Court address the issue of consent?	The Court noted that the absence of independent evidence of a romantic relationship was not a sufficient basis to dismiss the possibility of consensual sexual intercourse, which can arise from mutual attraction or lust.
What guidelines did the Court emphasize for deciding sexual abuse cases?	The Court highlighted the guidelines that accusations of rape can be made easily, that complainant testimony should be cautiously scrutinized, and that the Prosecution’s evidence must stand on its own merits.
What does this case say about the burden of proof in criminal cases?	This case reaffirms that the burden of proof lies with the prosecution to prove the accused’s guilt beyond a reasonable doubt and that the accused is presumed innocent until proven otherwise.

This case serves as a crucial reminder of the importance of the presumption of innocence and the high standard of proof required for criminal convictions. It underscores the need for careful and critical evaluation of evidence, particularly in sensitive cases like sexual assault, ensuring that justice is served fairly and impartially.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES vs. PACIFICO SANGCAJO, JR., G.R. No. 229204, September 05, 2018