[G.R No. 229204.
September 5,2018]
PEOPLE OF THE PHILIPPIENS, plaintiff – appellee,
vs.
PACIFICO SANGCAJO, JR., accused – appellant.
FACTS:
1. Petitioner’s/Plaintiff’s claim/s (no more than 3 sentences)
On February 1, 2009, when AAA submitted herself to medical examination at the same day
AAA and her grandmother went to the police station to report a crime. AAA accused her
mother’s cousin of the crime of rape which happened on January 30,2009 where AAA and the
accused were drinking beer because it was her birthday. After consuming two large bottles of
beer AAA felt dizzy and sleepy therefore she went to Pacifico’s papag and fell asleep but she
was awakened when she felt someone on top of her, who turned out to be the accused who
has been forcing himself inside of AAA, held her hand at the same time pinned down her feet
with his thighs; AAA passed out after 3 minutes and when she wake up the accused is lying
beside her and he was naked that’s why AAA traumatically went to take a bath, took her things
and went to her grandmother to tell what happened.
2. Respondent's/Defendant's claim/s (no more than 3 sentences)
The response of the accused Pacifico Sangcajo, Jr. claimed that the sexual congress between
him and AAA is consented and what happened between them was consensual sexual
intercourse. Pasifico testified that AAA used to live in his house and on January 30, 2009, he
arrived at the house and at the same time his wife was in San Juan. They drink Red Horse
because AAA asked the accused to drink with her and after one hour, she was tipsy, dizzy and
lazy to go to her own bed that’s why she was in Pasifico’s room and when Pasifico lied down,
they have physical contact, whereas AAA did not resist and have sexual intercourse with the
accused and she was pleased.
3. Decisions of the lower courts (e.g. RTC, CA)
RTC – The RTC convicted Pacifico of rape as charged. It found AAA credible and trustworthy,
nothing that she had even cried while recounting the details of the crime.
WHEREFORE, premises considered, the court finds accused, PACIFICO SANGCAJO, JR.,
guilty beyond reasonable doubt of the crime of RAPE and is hereby sentenced to suffer the
penalty of RECLUSION PERPETUA and to indemnify private complaint [AAA] the amount of
Fifty Thousand Pesos.
Court of Appeals – The CA affirmed the conviction, and declared that AAA had been
unconscious at the time Pacifico started to ravish her. It observed that suspicion of fabrication
on her part.
WHEREFORE, the trial court’s decision dated August 13,2014 is AFFIRMED, subject to
modification that accused-appellant is further ordered to pay AAA moral damages of Fifty
Thousand Pesos and exemplary damages of Thirty Thousand Pesos. In addition, to the civil
indemnity of 50,000 pesos awarded by the trial court, and to pay interest at the rate of six per
cent per annum on all the damages awarded, to be computed from date of finality of this
judgement until full payment.
ISSUE:
4. Issue/s (one sentence)
Whether or not the accused, Pacifico Sangcajo, Jr. is guilty of the crime of rape as charge.
HELD:
5. Disposition of the case (one sentence)
The Court REVERSES and SET ASIDE the decision promulgated on March 31, 2016 by the
Court of Appeals in CA-G.R CR-HC No. 07162 affirming the conviction for rape of accused-
appellant PACIFICO SANGCAJO, JR.; and, accordingly, ACQUITS him for failure of the
Prosecution to prove his guilt beyond reasonable doubt.
6. Dictum/Ratio Decidendi (no more than five sentences addressing the issue relevant to
the topic under discussion)
Jurisprudence has laid down guidelines on how the courts should proceed in deciding sexual
abuse cases. The guidelines are: (1) an accusation of rape can be made with facility, and while
the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to
disprove the accusation; (2) in the nature of things, only two persons are usually involved in
the crime of rape; hence, the testimony of the complainant should be scrutinized with great
caution; and (3) the evidence for the Prosecution must stand or fall on its own merits, and
cannot draw strength from the weakness of the evidence for the Defense.
Our careful and thorough review has turned up several circumstances that cast serious doubt
on the finding of Pacifico’s guilt for rape. The first circumstance related to the insistence of
Pacifico that AAA’s testimony contained material inconsistencies that demonstrated definite
improbabilities in her recollection commands our concurrence. Under the circumstances she
described in court, there were enough by which to doubt the veracity of her version. Hence, we
should not unquestioningly believe her thereon and thirdly, the lower courts’ justification for
their, rejection of Pacifico’s defense that the sexual intercourse had been consensual was
unfair and unreasonable.
