PEOPLE OF THE PHILIPPINES, vs. JUVY D. AMARELA AND JUNARD G. RACHO

G.R. No. 225642-43 January 17, 2018

Maria Clara Doctrine 

Facts: [AAA] was watching a beauty contest with her aunt held at a basketball court where a make-shift stage was put up. She had the urge to urinate so she went to the comfort room beside the building of the Maligatong Cooperative near the basketball court. Amarela suddenly pulled her towards the day care center. He placed himself on top of her and inserted his penis inside her vagina and made a push and pull movement. She shouted for help and then three (3) men came to her rescue [so] Amarela fled.

The three (3) persons brought her to a hut. But they closed the hut and had bad intentions with her. So she fled and hid in a neighboring house. When she saw that the persons were no longer around, she proceeded on her way home. She went to the house of Godo Dumandan who brought her first to the Racho residence because Dumandan thought her aunt was not at home. Dumandan stayed behind so Neneng Racho asked her son [Racho] to bring her to her aunt's house instead. [AAA] then said that [Racho] brought her to a shanty along the way against her will. He, then, undressed himself and placed himself on top of [AAA]. After consummating the act, [Racho] left her. So [AAA] went home alone.

For the defense, Amarela testified for himself denying that he had anything to do with what happened with AAA. On his part, Racho confirmed that he went with AAA to bring her home but also denied raping her.

The RTC found AAA's testimony, positively identifying both Amarela and Racho, to be clear, positive, and straightforward. Hence, the trial court did not give much weight to their denial as these could not have overcome the categorical testimony of AAA. 

Issue: Whether the testimony of the offended party sufficient to convict the accused

Held: 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. And while the factual setting back then would have been appropriate to say it is natural for a woman to be reluctant in disclosing a sexual assault; 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 of a woman's dynamic role in society today; she who has over the years transformed into a strong and confidently intelligent and beautiful person, willing to fight for her rights.

The following circumstances, particularly, would cast doubt as to the credibility of AAA's testimony: (1) the version of AAA's story appearing in her affidavit-complaint differs materially from her testimony in court; (2) AAA could not have easily identified Amarela because the crime scene was dark and she only saw him for the first time; (3) her testimony lacks material details on how she was brought under the stage against her will; and (4) the medical findings do not corroborate physical injuries and are inconclusive of any signs of forced entry.

WHEREFORE, premises considered, the 26 June 2012 Joint Judgment of the Regional Trial Court, Branch 11 of Davao City, in Criminal Case Nos. 64964-09 and 64965-09, as well as the 17 February 2016 Decision of the Court of Appeals in CA-G.R. CR HC Nos. 01226 and 01227-MIN are hereby REVERSED and SET ASIDE.

Accused-appellants Juvy D. Amarela and Junard G. Racho are ACQUITTED of the charge of rape on the ground of reasonable doubt. Their IMMEDIATE RELEASE from custody is hereby ordered unless they are being held for other lawful cause.