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G.R. No. 219850

In the case of People of the Philippines vs. Ron Ron San Pedro, the accused was charged with raping a deaf and mute woman, AAA, who testified that she was assaulted while unconscious. The Regional Trial Court initially found Ron Ron guilty, but upon appeal, the Court of Appeals modified the ruling and ultimately the Supreme Court acquitted him, citing reasonable doubt regarding the non-consensual nature of the encounter. The Supreme Court emphasized the prosecution's failure to prove guilt beyond reasonable doubt, leading to Ron Ron's release from detention.

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0% found this document useful (0 votes)
114 views5 pages

G.R. No. 219850

In the case of People of the Philippines vs. Ron Ron San Pedro, the accused was charged with raping a deaf and mute woman, AAA, who testified that she was assaulted while unconscious. The Regional Trial Court initially found Ron Ron guilty, but upon appeal, the Court of Appeals modified the ruling and ultimately the Supreme Court acquitted him, citing reasonable doubt regarding the non-consensual nature of the encounter. The Supreme Court emphasized the prosecution's failure to prove guilt beyond reasonable doubt, leading to Ron Ron's release from detention.

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CASE NO.

5
1. TITLE
• People of the Philippines vs. Ron Ron San Pedro y Servano
• G.R. No. 219850
• https://www.chanrobles.com/cralaw/2021julydecisions.php?id=831
2. PROMULGATION DATE
• July 14, 2021
3. PONENTE OF THE CASE
• Justice Gaerlan
4. NATURE OF THE FILED PETITION

5. NATURE OF THE CASE
• Crime against Person- Rape
6. COURT WITH ORIGINAL JURISDICTION
• Regional trial court
7. COURT WHERE THE CASE HAS BEEN FILED
• Regional Trial Court of xxxxxxxxxxx City, Branch 133
8. SESSION IN THE SUPREME COURT
• First division
9. MAJOR FIELD OF LAW
• Criminal law
CASE DIGEST
FACTS:
Ron Ron was criminally charged with raping AAA, a deaf and mute 19-year-old woman. The
undersigned Prosecutor accuses RON RON SAN PEDRO y SERVANO of the crime of rape by
means of force and intimidation, did then and there willfully, unlawfully, and feloniously have
carnal knowledge of complainant [AAA] who is deaf and mute, against her will and
consent.Upon arraignment, Ron Ron pleaded not guilty.
Version of the Prosecution
By writing and through a sign language interpreter, AAA testified that on the night of July 6,
2010, she went to her friend Matet's house for a drinking session. One of the persons present
at the drinking session was the accused, Ron Ron. AAA and Ron Ron left Matet's house together
to buy food, and they ended up eating at AAA's house. AAA went upstairs after Ron Ron
gestured for her to follow him, but she didn't because she was still smoking. When AAA later
went upstairs, she found Ron Ron asleep on her bed. She lay down beside him and fell asleep.
When she woke up, she discovered that her denim shorts had been removed, and Ron Ron was
on top of her. AAA tried to resist by punching Ron Ron, but he overpowered her and raped her.
After the incident, Ron Ron fled the scene, but AAA followed him to Matet's house. Ron Ron
threatened AAA with a knife, but she managed to persuade him to put it down, AAA then went
to the police station to report the event, and Ron Ron was initially arrested but released after
AAA agreed not to press charges. BBB, AAA's mother, later went to the police station to inform
them that the complaint against Ron Ron should not be withdrawn without her consent, as her
daughter is a deaf-mute. Ron Ron was arrested again after BBB's intervention. AAA underwent
a medico-legal examination, which revealed injuries to her genital area, including a fresh
laceration on her hymen. Testimony was provided by BBB, Dr. Cordero (the pathologist who
conducted the medico-legal examination), and PO3 Umali (the police officer involved in the
investigation). Various documentary exhibits, such as sworn complaints, statements, medico-
legal reports, and investigation reports, were presented as evidence.
Version of the Defense
Ron Ron, who was 21 y/o at that time, admitted to having sexual intercourse with AAA on July
7, 2010, but claimed that it was consensual. Ron Ron stated that he and AAA had known each
other since 2005 and communicated through sign language, text messaging, and social media.
They had gone out together on several occasions and had engaged in drinking sessions. On the
night of the incident, Ron Ron was having a drinking session at his residence with AAA and two
others. AAA invited Ron Ron to continue drinking at her house, and he agreed. They went to
AAA's house, where Ron Ron initially lay on the sofa but was later invited by AAA to go upstairs
to her room. Ron Ron lay down on AAA's bed, and she joined him a few minutes later.
According to Ron Ron, AAA initiated physical contact and they ended up having sexual
intercourse. However, Ron Ron soon realized the situation and got dressed. AAA followed Ron
Ron back to his house, where they were confronted by Matet, who referred to Ron Ron as her
husband. AAA admitted to Matet that she had sexual intercourse with Ron Ron. AAA later
apologized to Matet for her actions. Ron Ron was initially released after AAA withdrew her
complaint, but he was later arrested again when BBB, AAA's mother, complained that Ron Ron
had raped AAA. The defense presented a certified true copy of the police blotter as evidence,
indicating that AAA had agreed to withdraw her complaint.
ISSUE:
Whether or not AAA consented Ron Ron with his act.
RULING:
RTC Ruling
The trial court found the prosecution's version more credible. The Court puts weight and
credence to the testimony of the victim as it was unshaken, straightforward, and categorical in
all aspects specifically the fact that when she woke up the shorts she was then wearing was
already off only to find out consequently that [Ron Ron] had sex with her while she was fast
asleep and drunk, ergo unconscious. Also, in keenly observing the demeanor of the
complainant while testifying, it was apparent that she displayed an honest deportment with
unrehearsed declarations. The declaration of the private complainant that she was a victim of
rape is confirmed by the testimony of the MedicoLegal Officer and supported by documentary
evidence such as the Medico-Legal Report No. R10- 1300.
WHEREFORE, premises considered, with the prosecution having proved the guilt of the
accused beyond reasonable doubt for the crime of Rape, under Article 266-A of the Revised
Penal Code, as amended by Republic Act No. 8353, the accused RON RON S. SAN PEDRO is
hereby sentenced to suffer the penalty of Reclusion Perpetua.
Pursuant to the existing jurisprudence, the accused is further ordered to indemnify the
private complainant, [AAA], the amount of P50,000.00 as moral damages and P25,000.00 as
and by way of exemplary damages.
The Jail Warden of the ███████████ City Jail or any Officer of the Law who is in
custody of the accused, he being a detained prisoner, is ordered to commit the accused to the
Bureau of Corrections, Muntinlupa City.
The defense filed a notice of appeal, which was admitted by the trial court. The parties filed
their respective briefs before the CA.
Ruling of the CA
The CA sustained the trial court's findings and conclusions, ruling that AAA's positive,
categorical, and straightforward testimony prevails over Ron Ron's defense of denial and alibi
which was not supported by clear and convincing evidence. The defense was unable to prove
that AAA had ill motive to testify against Ron Ron. The CA modified the penalty upon finding
that the trial court failed to award civil indemnity in favor of AAA and to impose legal interest.
WHEREFORE, premises considered, the Decision of the Regional Trial Court in Criminal
Case No. 10-1257 finding herein appellant guilty beyond reasonable doubt of the crime of rape
is hereby AFFIRMED with the MODIFICATIONS that: (1) AAA is further awarded the amount of
50,000.00 as civil damages; and (2) appellant is further ordered to pay AAA interest on all
damages at the legal rate of 6% per annum from the date of the finality of this judgment.
The defense filed a notice of appeal, which was admitted by the trial court. The parties filed
their respective briefs before the CA.
The Court's Ruling
Under Article 266-A of the RPC as amended, the crime of rape can be committed either
through sexual intercourse132 or by sexual assault.133 To prove rape by sexual intercourse, the
prosecution must prove the following elements beyond reasonable doubt: (i) that the accused
had carnal knowledge of the victim; and (ii) that said act was accomplished (a) through the use
of force or intimidation, or (b) when the victim is deprived of reason or otherwise unconscious,
or (c) by means of fraudulent machination or grave abuse of authority, or (d) when the victim is
under 12 years of age or is demented.
Here, Ron Ron admits having sexual intercourse with AAA; but asserts that the same was
consensual and not consummated through force or intimidation. In so doing, the defense
essentially argues that it was AAA who lured Ron Ron to her bed. On the contrary, AAA argues
that Ron Ron forced himself upon her.
Consent to sex does not only cover the physical act. Sex does not only involve the body,
but it necessarily involves the mind as well. It embraces the moral and psychological
dispositions of the persons engaged in the act, along with the socio-cultural expectation
and baggage that comes with the act. For instance, there are observed differences in
sexual expectations and behaviors among different genders, and more so, among
individuals. The wide range of sexual desire and behavior are not only shaped by
biology, but by culture and prevailing norms as well. Full and genuine consent to sex,
therefore, is "preceded by a number of conditions which must exist in order for act of
consent to be performed."
Pivotal to the resolution of this case is the ability of AAA to give and to communicate her
consent to the sexual act. Given the specific personal circumstances of AAA, who communicates
primarily through hand gestures and electronic text input/output devices, this Court, guided by
the foregoing jurisprudential precepts, has painstakingly reviewed the record to determine if
AAA had consented to having sexual intercourse with Ron Ron. This Court concludes that the
prosecution was unable to establish Ron Ron's guilt beyond reasonable doubt. Despite AAA's
categorical testimony of the incident and the medico-legal results showing injuries on her
hands, there are several material circumstances on record which create reasonable suspicion as
to the non-consensuality of the sexual encounter in question

• After AAA first reported the incident to the police, she decided not to press charges
against Ron Ron, because she thought that the entire incident was a mere
"misunderstanding." This is reflected in the police blotter entry for the incident.
• AAA categorically admitted that after she signed the police blotter and went home, her
mother BBB learned of the incident and demanded that they file a complaint against
Ron Ron:
• As pointed out by Justice Caguioa, Matet's testimony fills in the details missed by AAA
about the confrontation at Matet's house. Their testimonies, when read together, casts
doubt about the non-consensuality of the immediately preceding sexual encounter
between Ron Ron and AAA. From their combined testimonies, it becomes clear that:
1. 1after the sexual encounter, AAA followed Ron Ron to Matet's house;
2. AAA and Ron Ron had an altercation outside the house involving a knife;
3. Matet sensed the commotion, went outside to look, and saw Ron Ron and AAA;
4. when Matet asked about what happened, AAA communicated through Matet's
cellphone her admission that she had sexual intercourse with Ron Ron;
5. Ron Ron explained the incident to Matet and asked for forgiveness; and
6. while Ron Ron and Matet were talking, AAA left and went to the barangay on her
own.
• Matet's testimony and the medico-legal findings indicate that the altercation between
Ron Ron and AAA did involve a pointed object, which both AAA and Ron Ron claimed to
be a knife. At some point in that altercation, AAA held the knife to Ron Ron, who then
restrained the former's hands while she was holding said knife. The force and pressure
from Ron Ron's restraint could have been the source of the contusions found at the
back of AAA's hands. In the course of this apparent struggle for control of the knife, its
blade grazed AAA's index finger, causing the abrasion wound. Given the conflicting
accounts provided by Ron Ron and AAA as to who was holding the knife and why Ron
Ron produced it in the first place, only they truly know what transpired in that
altercation. The Court thus cannot speculate on the precise chain of events that led to
the aforementioned struggle.
• Matet categorically testified that almost a year after the incident, AAA apologized for
"what she had done to Ron-ron,"
The circumstances presented, supported by the case records, create reasonable doubt
regarding whether the sexual encounter between Ron Ron and AAA was non-consensual. The
issue of consent in such cases is deeply personal and cannot be presumed or speculated upon
by the courts. In a similar case involving two teenagers, the court acknowledged the existence
of various possibilities and expressed its inability to fill in the missing details. The court
emphasized that it is the duty of the parties involved to provide the necessary evidence and
that the prosecution plays a crucial role in examining witnesses to uncover important elements
of the crime. In any criminal case, including rape, the law requires proof beyond reasonable
doubt to secure a conviction. The prosecution's evidence must eliminate all reasonable doubt
regarding the accused's guilt. Ultimately, the responsibility of passing righteous judgment lies
with a higher authority.

WHEREFORE, the present appeal is GRANTED. The November 11, 2014 Decision of the Court of
Appeals in CA-G.R. CR HC No. 06052 affirming with modification the February 13, 2013 Decision
of the Regional Trial Court of ███████████ City, Branch 133 in Criminal Case No. 10-1257,
is REVERSED and SET ASIDE. Accused-appellant Ron Ron San Pedro y Servano is ACQUITTED for
failure of the prosecution to prove his guilt beyond reasonable doubt. His immediate RELEASE
from detention is hereby ORDERED, unless he is being held for another lawful cause.

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