PEOPLE OF THE PHILIPPINES v RONNIE R.
LIBRIAS
G.R. No. 208067
September 14, 2016
Case digested by: Annalou T. Amascual
FACTS:
Librias was charged with Forcible Abduction with Rape in relation to R.A. No.
7610 or Special Protection of Children Against Abuse, Exploitation and Discrimination
Act.
AAA testified that on September 14, 2003, at around 9:00 P.M. at the Mandaue
Plaza while she was waiting for her cousin, she was approached by Librias who
threatened to kill her if she would not go with him. Librias and AAA left the plaza and
boarded a taxi and headed to Colon Street in Cebu City. AAA was trying to open the
door of the taxi but Librias held her hands down.
Upon reaching Colon Street, Librias and AAA walked towards a house where
they were given their own private room with its own bed. When they were already
inside, Librias slowly started taking off AAA’s clothes. AAA struggled but was
overpowered as Librias held her hands and pinned her down with her legs and did his
sexual advances.
AAA made her escaped when Librias fell asleep and proceeded to the Barangay
Hall of Ibabao which she reported the matter to the barangay officials and Librias was
arrested and was brought to the nearest police station.
In his defense, Librias testified that he did not force or threaten AAA to have
sexual intercourse with him; much less did he hold her against her will when he brought
her to the Hidden Lounge in Cebu City.
Librias testified that after lighting a candle at the nearby church, he proceeded to
Mandaue Plaza to meet his ex-girlfriend. While he was in the park, he noticed a woman
who was seated right across from him, smiling at him. Librias smiled back and they
introduced themselves to one another. They started flirting and strolled around the plaza
for an hour and a half. AAA invited Librias to join her and her friends at a disco. Librias
declined but invited AAA to go to a videoke bar instead. AAA acceded and they boarded
a taxi and proceeded to Colon Street in Cebu City.
Librias took AAA to his cousin store but his cousin was not there so Librias
offered AAA to take her home but AAA refused and insisted that she would just stay
with him. Thus, they walked to Hidden Lounge where they checked in for two (2) hours.
Librias narrated that after their intimate act, AAA asked him for money so that
she could go home. Librias told her to wait as he had to go to the comfort room. When
Librias came out from the comfort room, he saw AAA boarded a taxi. Recalling where
AAA said she lived, he proceeded to her residence. He waited AAA to come outside at
her house in a nearby bar. However, AAA came out and had the barangay tanods arrest
him.
RTC’s Decision
The RTC did not give much credence to Librias’ denial in the light of AAA’s
positive declaration that Librias had held her against her will and raped her.
CA’s Decision
The Court of Appeals affirmed Libria’s conviction in toto. It held that AAA’s
version of what transpired was more credible and believable.
Supreme Court’s Decision
Crimes against chastity, as well as the crime of rape, usually involve only two (2)
persons: the victim-complainant and the alleged offender. As a consequence, the
conviction or acquittal of the accused depends almost entirely on the credibility of the
complainant’s testimony as seldom is there an eyewitness, other than those involved, to
the commission of the offense.
The Court finds that AAA’s testimony raised serious doubts in the truthfulness of
her statements.
First, AAA’s narration that Librias forcibly took her from Mandaue Plaza to a
house on Colon Street, Cebu City, is very unlikely considering that AAA testified that the
plaza was not completely deserted and that there were few people around. AAA could
have easily escaped or have called for help. Hence, the foregoing statements of AAA
would suggest that she was not really held against her will.
The lower court’s decision that AAA could not think of a way to escape because
she was afraid is a mere conjecture that cannot support a conviction. As general rule,
the Court is bound by the trial court’s findings of fact and evaluation of credibility of
witnesses, especially when affirmed by the appellate court. However, this time-honored
doctrine admits exceptions, such as when the trial court overlooked, misunderstood, or
misapplied facts or circumstances of weight and substance that would affect the result
of the case.
The Court is guided by the equipoise rule: where the evidence in criminal case is
evenly balanced, the constitutional presumption of innocence tilts the scale in favor of
the accused. Thus, where the inculpatory facts and circumstances are capable of two or
more explanations, one of which is consistent with the innocence of the accused and
the other consistent with his guilt, then the evidence does not fulfill the test of moral
certainty and is not sufficient to support a conviction. Applying this rule, the Court
conclude that AAA did not try to escape or call for help because she wanted to go to
wherever Librias was planning to bring her.
Second, AAA gave different statements as to how she was held back by Librias
during the taxi ride going to Colon Street, Cebu City. In her direct testimony, she said
that Librias was holding her hands the whole time while he was flagging down a taxi cab
and when he pushed her inside. However, upon further cross examination, she stated
that Librias tied her hands with a towel to restrict her movement.
AAA’s statements as to how Librias brought her to the taxicab buttress the
conclusion that she voluntarily went with him. While rape victims are not required or
expected to remember all the details of their harrowing experience, this inconsistency
drawn from AAA’s contradicting testimonies cannot be considered as minor that would
not affect her credibility.
Third, AAA’s version on how she was raped likewise raises doubt as to whether
the sexual intercourse initiated by Librias was against her will. Allegedly, Librias did his
sexual advances by using his hands to restrain AAA’s hands and his legs to hold her
down. This means that AAA’s legs were pinned underneath the legs of Librias. This
position would make sexual intercourse very difficult when the entry to the latter would
be closed with her legs supposedly pinned and thus restrained from opening.
The Court has a double plus in favor of the defense. The first plus factor is the
weakening of the prosecution’s case for almost solely relying on the testimony of AAA
which has raised serious doubts that would not support a conviction. The second plus
for the defense is Librias’ denial, which was straightforward and needed no elaborate
analysis to understand. He was walking around Mandaue Plaza where he met this girl
who caught his attention. They were initially attracted to each other; hence, they started
flirting. Not long after, they did not want the night to end so soon and wanted to take
their newly found attraction further. This is simply a case of a one-night stand that went
bad. Given these facts and the shaky evidence presented by the prosecution, Librias’
denial is all that is needed to acquit him.
The Court reverse and set aside the decision of the Court of Appeals and
acquitted Ronnie Librias for failure of the prosecution to prove his guilt beyond
reasonable doubt.
