CASE DIGEST : PEOPLE v. RON RON SAN PEDRO Y SERVANO GR 219850 GAERLAN

[ GR No. 219850, Jul 14, 2021 ]

PEOPLE v. RON RON SAN PEDRO Y SERVANO                                                                                                    

FACTS : Ron Ron San Pedro was charged with raping AAA, a deaf and mute 19-year-old. The prosecution alleged that he took advantage of AAA’s condition, while the defense claimed that the intercourse was consensual. AAA testified—through writing and an interpreter—that she was drunk, fell asleep, and awoke to find Ron Ron on top of her; medical findings confirmed recent lacerations and injuries consistent with sexual assault. Ron Ron admitted to intercourse but argued consent, supported by his partner Matet, who claimed AAA later apologized. The RTC found AAA’s testimony credible, corroborated by physical evidence, and convicted Ron Ron of rape, sentencing him to reclusion perpetua with damages. On appeal, the CA affirmed the conviction, holding that AAA’s consistent and convincing testimony outweighed Ron Ron’s unsubstantiated claim of consent and lack of ill motive on AAA’s part.

ISSUE  : WON the CA is coorecr

HELD :The Court emphasized that under Article 266-A of the Revised Penal Code, rape can be committed either by sexual intercourse or sexual assault, and conviction requires proof beyond reasonable doubt of carnal knowledge through force, intimidation, or lack of consent. While Ron Ron admitted to intercourse with AAA, a deaf-mute, he claimed it was consensual. The Court, after reviewing the evidence, found several factors creating reasonable doubt. AAA initially told police it was a "misunderstanding" and signed a blotter entry with assistance, later re-filing the case only at her mother’s insistence. Testimonies and medico-legal findings showed an altercation involving a knife, consistent with both parties’ accounts, but unclear on who initiated force. AAA’s friend Matet, who was close to both, corroborated parts of both sides and testified that AAA later apologized for what she had done. Given these inconsistencies and doubts about the non-consensual nature of the encounter, the Court ruled that the prosecution failed to prove guilt beyond reasonable doubt, underscoring the principle that conviction for rape requires clear, convincing, and credible evidence free from reasonable doubt.