View full case

PEOPLE v. PACIFICO SANGCAJO

FACTS:

The accused-appellant in this case is Pacifico Sangcajo, Jr. He seeks the reversal of the decision of the Court of Appeals (CA) which affirmed his conviction for rape. The Office of the City Prosecutor of Quezon City filed a case charging Pacifico with rape, alleging that on January 30, 2009, in Quezon City, Pacifico committed an act of sexual intercourse upon the person of one AAA without her consent. Pacifico is the cousin of AAA's mother and on the said date, AAA was temporarily residing at Pacifico's house while waiting for her oath-taking as an employee of the Bureau of Jail Management and Penology (BJMP). On the night of the incident, AAA and Pacifico were drinking together to celebrate AAA's birthday. AAA eventually felt dizzy and sleepy, and Pacifico allowed her to lie down on his bed. However, AAA was awakened when she felt Pacifico on top of her. Pacifico held AAA's hands and pinned down her feet, and then proceeded to have sexual intercourse with her against her will. AAA passed out and when she woke up the next morning, she saw Pacifico lying naked beside her. She immediately reported the incident to her grandmother, who then arranged for her to go to the police station for medical examination. The medical examination confirmed recent vaginal penetration. Pacifico denied the charges and claimed that the sexual intercourse was consensual.

The case involves the rape of AAA, who was the wife of the accused Pacifico Sangcajo, Jr. On the day of the incident, AAA and Pacifico were alone in their house as AAA's wife was in San Juan. AAA asked Pacifico to fix her hair, and while doing so, AAA asked Pacifico to drink with her as it was her birthday. They consumed two bottles of Red Horse beer. When AAA became tipsy, she asked permission to lie on Pacifico's bed, and he agreed. After clearing the table and washing the glasses, Pacifico lied down next to AAA. He turned off the lights, embraced AAA, and they had sexual intercourse. Pacifico then kissed her and they fell asleep. When Pacifico woke up, AAA was having coffee, and he apologized to her. Later, when Pacifico woke up again, AAA was gone.

During the trial, AAA testified along with a Medico-Legal Officer from the Philippine National Police Crime Laboratory. Pacifico presented himself as a witness and his neighbor, Jelleve Loreja.

The Regional Trial Court (RTC) convicted Pacifico of rape, finding AAA credible and the elements of the crime established. Pacifico's defense of consent was not accepted as the court believed AAA would not willingly subject herself to the shame and scandal of testifying on her defilement unless the charge were true.

The Court of Appeals (CA) affirmed the conviction, stating that AAA was unconscious during the sexual act. It found no evidence of fabrication and concluded that the act was not consensual due to the absence of proof of a romantic relationship.

Pacifico appealed the decision.

ISSUES:

  1. Whether AAA's testimony was credible and sufficient to establish guilt beyond reasonable doubt.

  2. Whether AAA's testimony should be scrutinized with great caution due to the nature of rape cases.

  3. Whether there are material inconsistencies in AAA's testimony that cast doubt on Pacifico's guilt for rape.

  4. Whether the lower courts' rejection of Pacifico's defense of consensual sexual intercourse was unfair and unreasonable.

  5. Whether the guilt of the accused for rape was established beyond reasonable doubt.

  6. Whether the accused is entitled to be acquitted and released.

RULING:

  1. The Court acquits Pacifico due to reasonable doubt of his guilt.

  2. Yes. The Court found that there were material inconsistencies in AAA's testimony that raised doubts about the veracity of her version of events. AAA's description of the sexual assault was physiologically improbable and lacked supporting physical evidence, such as injuries or resistance. Therefore, credence should not be accorded to her testimony.

  3. Yes. The lower courts' rejection of Pacifico's defense of consensual sexual intercourse was unfair and unreasonable. The Court noted that AAA and Pacifico had been drinking alcohol and that AAA's conduct indicated a level of comfort and willingness to be alone with Pacifico. Given these circumstances, the defense of consensual sexual intercourse was more likely to be true than not.

  4. The Court reversed and set aside the decision affirming the conviction for rape of the accused. The Court acquitted the accused for failure of the prosecution to prove his guilt beyond reasonable doubt. The Court further ordered the immediate release of the accused from the National Penitentiary, unless there are other lawful causes warranting his continuing confinement thereat.

PRINCIPLES:

  • An accusation of rape can be made with facility, and while it is difficult to prove, it is even more difficult for the accused, though innocent, to disprove the accusation.

  • The testimony of the complainant in a rape case should be scrutinized with great caution.

  • 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.

  • The trial court's evaluation of the evidence and credibility of witnesses is accorded the highest respect on appeal.

  • The credibility of testimony given in judicial trials is tested by human experience and probability.

  • Courts should not rely on evidence that is inherently or physically improbable.

  • The State has the burden to overcome the presumption of innocence in favor of the accused.

  • The mere invocation of traditional cultural norms or assumptions about a victim's modesty does not dispense with the requirement to present sufficient evidence to overcome the presumption of innocence.

  • Reasonable doubt of guilt should be based on evidence or the lack of it, and not on sympathy or a dislike for convicting a fellow man.