People v. Sison
REITERATIONFacts
The Antecedents: Complainant Violeta Begino y Aquino accused the defendant-appellant, Ernesto Sison y Aviles, of forcible abduction with rape. She alleged that on July 15, 1973, in Quezon City, Sison, with lewd design, forcibly dragged her into a tricycle, brought her to a house in Novaliches, and there had carnal knowledge of her by means of force and intimidation, against her will. The complainant was approximately 15 years and 10 months old at the time, working as a housemaid. Procedural History: The trial court convicted the appellant of forcible abduction with rape and sentenced him to reclusion perpetua, with indemnity and costs. The appellant appealed this conviction. The Petition: The defendant-appellant contested his conviction, raising issues regarding the credibility of the complainant's testimony and the sufficiency of the evidence to prove forcible abduction with rape.
Issue(s)
Whether the prosecution sufficiently proved the crime of forcible abduction with rape beyond reasonable doubt. Whether the complainant's testimony regarding the alleged abduction and rape was credible and consistent with the surrounding circumstances.
Ruling
The Supreme Court acquitted the appellant, Ernesto Sison y Aviles, of the charge of forcible abduction with rape. The Court found the complainant's narration of events to be incredible and inconsistent with the physical realities and common human behavior, thereby failing to establish guilt beyond reasonable doubt. The Court ordered the immediate release of the appellant unless held for other valid charges.
Ratio Decidendi
On the issue of whether the prosecution sufficiently proved the crime of forcible abduction with rape beyond reasonable doubt: The Court found that the complainant's testimony was replete with inconsistencies and improbabilities that cast serious doubt on the alleged forcible abduction and rape. The Court noted that the complainant, a minor, claimed to have been forcibly dragged into a tricycle and then a jeepney, traveling significant distances through populated areas, without any attempt to resist, shout for help, or attract attention from numerous bystanders, drivers, or even policemen. The Court also found it incredible that she did not complain to the appellant's aunt or other housemates during the six days she stayed with him, despite allegedly being subjected to repeated sexual intercourse. The Court concluded that these circumstances negated the element of force and intimidation essential for forcible abduction and rape. On the issue of whether the complainant's testimony regarding the alleged abduction and rape was credible and consistent with the surrounding circumstances: The Court extensively analyzed the complainant's account, highlighting several points that undermined her credibility. These included her failure to cry for help while in the tricycle and jeepney, her alleged submission to repeated sexual acts without any signs of struggle or commotion in the house, and the lack of any report from her mother or employer about her disappearance for six days. The Court took judicial notice of the geography and population density of Metro Manila, emphasizing that it would have been highly improbable for the alleged acts of force and intimidation to occur without any witnesses or any reaction from the complainant. The Court also pointed out that the complaint did not allege the essential elements for consented abduction, such as the victim being a virgin over 12 but under 18 years of age, which would have been a different offense. Ultimately, the Court concluded that the complainant voluntarily went with the appellant and submitted to his designs, thus acquitting him of the charge.
Main Doctrine
The Court acquitted the accused due to the incredible and inconsistent narration of the complainant, which cast doubt on the commission of the crime of forcible abduction with rape. The circumstances indicated that the complainant voluntarily went with the appellant and submitted to his advances, negating the element of force and intimidation required for forcible abduction.