Rarely that the Supreme Court reversed the conviction of an accused by the Regional Trial Court and affirmed by the Court of Appeals. This only disproves the notion that our justice system is flawed. There are other criminal cases where the Supreme Court is always on guard to protect one’s constitutional rights and to correct the errors of the trial and appellate courts to see to it that justice is served. One of those cases is People v. Amarela & Racho, G.R. No. 225642-43 dated 17th January 2018 where the conviction of the two accused for rape was reversed changing the doctrine of Maria Clara or women’s honor. The facts of the case and the beauty of the reason and wisdom of the Supreme Court are summarized as follows:
Based on the testimony of the alleged rape victim [AAA], she was with her aunt watching a beauty contest held at a basketball court where a make-shift stage was put up. She went to the comfort room, but was not able to reach because Amarela suddenly pulled her toward the day care center and pulled her under the 2-foot stage where she was raped. Amarela fled after she shouted for help and three men came, who brought her to a hut. As she sensed their bad intention, she fled and hid and later proceeded on her way home. But, instead of going home, she went to a friend, who brought her first to the residence of Racho, who was told to bring her to her aunt’s house. But, Racho bought her to a shanty against her will, where she was raped again. AAA went home. Her parents were asleep. She left the next morning. Later, she told her mother, who reported to the police that led to the arrest of Amarela and Racho.
After a joint trial, the Regional Trial Court [RTC] rendered a joint decision convicting the two accused based on AAA’s lone testimony positively identifying the two. On appeal, the two argued that AAA’s claim is not credible. But, the Court of Appeals [CA] affirmed the RTC decision. It found AAA’s testimony straightforward and credible. It also ruled that the People has proven the existence of the elements of rape.
The Supreme Court ruled that more often than not, where the alleged victim survives to tell her story of sexual· depredation, rape cases are solely decided based on the credibility of the testimony of the private complainant. In doing so, we have hinged on the impression that no young Filipina of decent repute would publicly admit that she has been sexually abused, unless that is the truth, for it is her natural instinct to protect her honor. This misconception, particularly in this day and age, not only puts the accused at an unfair disadvantage, but also creates a travesty of justice. The “women’s honor” doctrine started in in 1960. xxx. xxx today, we simply cannot be stuck to the Maria Clara stereotype of a demure and reserved Filipino woman. We, should stay away from such mindset and accept the realities xxx. In this way, we can evaluate the testimony of a private complainant of rape without gender bias or cultural misconception. It is important to weed out these unnecessary notions because an accused may be convicted solely on the testimony of the victim xxx. Thus, in order for us to affirm a conviction for rape, we must believe beyond reasonable doubt the version of events narrated by the victim.
In an appeal from a judgment of conviction in rape cases, the issue boils down, almost invariably, to the credibility and story of the victim and eyewitnesses. Although we put a premium on the factual findings of the trial court, especially when they are affirmed by the appellate court, this rule is not absolute and admits exceptions, such as when some facts or circumstances of weight and substance have been overlooked, misapprehended, and misinterpreted.
In her affidavit, she was pulled away from the beauty contest stage to the day care center. But, in her testimony, she was pulled away from the cooperative. From this, AAA would like us to believe that Amarela was able to undress himself and AAA, and place himself on top of her while under a 2- feet high makeshift stage. It is physically impossible for two human beings to move freely under a stage. The medical certificate shows AAA had no physical injuries. The absence of bruises on AAA’s thighs reinforces the theory that she may have had consensual intercourse. Thus, Amarela and Racho are entitled to an acquittal as their guilt was not proven beyond reasonable doubt.
