Case Digest: PEOPLE OF THE PHILIPPINES v. MICAHEL MURO 575 SCRA 493 (2008)

PEOPLE OF THE PHILIPPINES v. MICAHEL MURO 575 SCRA 493 (2008)

Inconsistencies on important details create doubts on the guilt of the accused. Michael Muro (Muro) was tried and convicted by the Regional Trial Court of Mandaluyong City of raping AAA a deaf-mute. AAA, at the witness stand, testified that she was grabbed by Muro outside her house in Mandaluyong, took her to a vacant lot with a lot of trees and water, and there had carnal knowledge of her. She said that she did not go home immediately and instead, spent the night in a stranger‘s house. The following day, she was picked up by a person on board a motorcycle who brought her to the barangay hall. Soon after, her mother BBB arrived together with Muro. She then informed the police what had happened to her and pointed to Muro as the culprit. Muro interposing alibi and claimed that he was a someplace else with his friends during the time of the alleged rape. He claimed that on his way home, he met a barangay tanod who was with AAA. He went with AAA to the barangay hall because he knew her. When they reached the hall, Muro asked the tanod what happened to AAA, and the barangay tanod answered him that eight men took turns in abusing her in Mangahan. He was also told that if AAA‘s parents do not fetch her, they would be sued and AAA would be turned over to the Department of Social Welfare. He thus offered to fetch AAA‘s parents and thereupon, he was surprised when AAA pointed to him as her attacker. The RTC found Muro guilty of the crime of rape and sentenced him to reclusion perpetua. On appeal,, the appellate court affirmed the RTC decision. Hence, this appeal. 

ISSUE:

Whether or not Michael Muro is guilty of rape beyond reasonable doubt

HELD:

The uncorroborated testimony of the victim in a rape case may, under certain circumstances, be adequate to warrant conviction. The testimony must, however, be clear, impeccable and ring true throughout or bear the stamp of absolute candor, free from any serious contradictions. The version of AAA at the witness stand and that given in her complaint-affidavit which she identified in court contain discrepancies. In her complaint-affidavit, AAA claimed that on appellant‘s invitation, they walked and conversed until they reached the vacant lot where he suddenly grabbed her, forcefully removed her short pants and panties, slapped her causing her to fall down, raped her, threatened to hurt her should she narrate what happened, and then left. At the witness stand, she, however, claimed that appellant grabbed her from outside her residence and brought her to the alleged watery vacant lot at J. Rizal Street where she accidentally tripped after which he raped her, put on his clothes, and left. On cross-examination, AAA claimed that that was her first time to have sexual intercourse. In her complaint-affidavit, however, AAA claimed that appellant had previously raped her three times, and that a certain Nonoy had been raping her everyday except Sundays from May 3, 1999 to May 30, 1999. Such inexplicable discrepancies on important details vis a vis the result of her physical examination which bears no indication of the commission of sexual intercourse committed hours earlier nag the Court to entertain serious doubts on whether appellant committed the crime charged.