327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a single instance of a sexual encounter, wherein the
victim alleges it was done under threat or intimidation, lead to the conviction
of the accused for the crime of rape if the alleged circumstances raise
reasonable doubt on the credibility of the victim's testimony?
People of the Philippines vs. Raymundo Rapiz y Correa
Date of Promulgation: September 16, 2020
Facts of the Case:
Raymundo Rapiz y Correa was charged with the crime of simple
rape allegedly committed against AAA, a 20-year-old woman who was related to
the accused as her mother's cousin. The prosecution claimed that on April 2,
2015, while AAA was alone in the house with the accused, he pointed a deadly
weapon at her, undressed her, and proceeded to have sexual intercourse with her
without her consent. After the incident, he allegedly threatened to kill her
and her mother if she disclosed the events.
The Regional Trial Court (RTC) of Las Piñas City convicted
Rapiz of rape, giving credence to the testimony of AAA, supported by the
medical findings of deep healed lacerations on her hymen. Rapiz was sentenced
to reclusion perpetua and ordered to pay civil indemnity and damages. On
appeal, the Court of Appeals affirmed the conviction but increased the amounts
of civil indemnity and moral damages to ₱75,000 each and added exemplary
damages of ₱75,000.
Rapiz argued that the accusations were fabricated due to a
grudge held by the victim's mother over a loan refusal. He also pointed to
inconsistencies in the victim's and her mother's testimonies about the dates of
the rape and the time it was reported. Additionally, he argued that the
victim's subsequent interactions with him, including meeting voluntarily and
going on outings, were inconsistent with the behavior of a rape victim.
Primary Legal Issue Before the Supreme Court:
Did the Court of Appeals err in convicting Raymundo Rapiz of
rape based on the evidence presented, despite the inconsistencies in the
victim’s testimony and the doubt cast on the alleged force, intimidation, or
moral ascendancy used?
Supreme Court Decision:
The Supreme Court acquitted Raymundo Rapiz on the
ground of reasonable doubt. The Court emphasized that while the lone testimony
of the victim can suffice to convict an accused, such testimony must be
credible, consistent, and free from contradictions. In this case, the Court
found significant gaps in the victim's narrative, including the failure to
describe the alleged deadly weapon and the lack of immediate resistance or
reporting. Moreover, the victim's actions after the alleged rape, including
willingly meeting and going on outings with the accused, raised doubts about
the coercion or intimidation element of the crime. The Court held that the
prosecution failed to prove beyond reasonable doubt that the sexual intercourse
was accomplished through force or intimidation.
Dispositive Portion:
The appeal is granted. The Decision of the Court of
Appeals is reversed and set aside. Raymundo Rapiz y Correa is acquitted
of the charge of rape on the ground of reasonable doubt. The Director of the
National Bilibid Prisons is ordered to release Raymundo Rapiz y Correa
immediately unless he is being held for another lawful cause.
Can a court convict an accused for rape if the victim’s
subsequent actions and the inconsistencies in her testimony suggest that the
alleged coercion or intimidation may not have occurred?
Important Doctrines Discussed:
- Reasonable
Doubt in Rape Cases:
"The constitutional presumption of innocence demands no less than moral certainty of guilt beyond a reasonable doubt, especially in rape cases where the only direct evidence is usually the testimony of the complainant." - Victim’s
Behavior Post-Rape:
"A woman’s conduct immediately after an alleged rape is of critical value in determining the truthfulness of her accusations. Inconsistent or voluntary interactions with the accused after the incident may cast doubt on the claim of lack of consent." - Force,
Threat, or Intimidation in Rape:
"The prosecution must prove that the sexual act was accomplished through force, threat, or intimidation, or that moral ascendancy was exerted over the victim to nullify her consent. Mere allegations of threats without further substantiation are insufficient."
This case is classified under Criminal Law.
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Read the full text here
🎓 INTRODUCTION BY A
PHILIPPINE LAW PROFESSOR:
Welcome, future lawyers and bar examinees! In this content,
we will dissect key legal doctrines from a landmark Philippine Supreme
Court case that challenged the reliability of a single testimony in rape
prosecutions. This case is essential for understanding how reasonable doubt
plays a pivotal role in criminal trials.
The goal of this video is to assist law students and bar
reviewees in memorizing and internalizing essential jurisprudence in Criminal
Law.
📌 CASE NATURE:
Criminal Law – Rape (Reasonable Doubt)
📚 CASE TITLE: People
of the Philippines vs. Raymundo Rapiz y Correa
Date of Promulgation: September 16, 2020
Parties: The People of the Philippines
(Plaintiff-Appellee) vs. Raymundo Rapiz y Correa (Accused-Appellant)
🧾 BRIEF SUMMARY:
Accused Raymundo Rapiz was convicted by the RTC and CA for
rape based on the lone testimony of a 20-year-old woman. However, the Supreme
Court acquitted him, citing reasonable doubt due to
inconsistencies in the complainant's testimony and lack of credible evidence on
force or intimidation.
❓Should a person’s liberty
hinge solely on one inconsistent testimony? Comment your take below.
📖 10 IMPORTANT DOCTRINES
FROM THE CASE:
- Reasonable
Doubt Must Be Based on the Evidence
"Where the evidence of the prosecution is weak, the
accused must be acquitted."
📖 People v. Rapiz,
G.R. No. 240662
- Victim’s
Lone Testimony Must Be Convincing
A rape conviction can rest on one testimony—but it must
be credible, consistent, and beyond reasonable doubt.
📖 People v. Rapiz
- Force
or Intimidation Must Be Proven, Not Presumed
Threats must be clear, specific, and sufficiently
intimidating to overcome the victim’s will.
📖 People v. Rapiz
- Weapon
Use Requires Clear Description
The complainant's failure to identify or describe the weapon
weakens the credibility of the alleged threat.
📖 People v. Rapiz
- Moral
Ascendancy Must Be Based on Legally Recognized Relationship
A cousin of the victim’s mother does not hold moral
ascendancy similar to a father or close kin.
📖 People v. Rapiz
- Post-Rape
Behavior Can Be Evaluated for Credibility
Victim’s voluntary interactions with the accused after the
incident can cast doubt on claims of rape.
📖 People v. Rapiz
- Inconsistencies
on Material Points Are Fatal
Discrepancies regarding the date and circumstances of the
rape erode credibility.
📖 People v. Rapiz
- The
Burden of Proof Rests on the Prosecution
Conviction must stand on prosecution's strength, not the
weakness of the defense.
📖 People v. Rapiz
- Absence
of Resistance Is Not Automatically Proof of Consent
But total passivity, when unsupported by real threats or
intimidation, is questionable.
📖 People v. Rapiz
- Judges
Must Scrutinize Rape Testimonies With Extreme Caution
Especially when the only direct evidence is the alleged
victim’s narration.
📖 People v. Rapiz
📌 FREQUENTLY ASKED
QUESTIONS:
Q1: What was the main reason for the Supreme Court’s
acquittal?
👉 Reasonable doubt due to
lack of credible threat, unclear testimony, and absence of coercion.
Q2: Did the Court find the complainant to be lying?
👉 Not necessarily. But
her testimony lacked the strength to meet the threshold of criminal conviction.
Q3: Can a rape conviction be based on one testimony?
👉 Yes, but only if it is
credible, consistent, and beyond reasonable doubt.
Q4: What damages were originally awarded?
👉 ₱75,000 each in civil
indemnity, moral damages, and exemplary damages.
Q5: Is moral ascendancy always sufficient to convict for
rape?
👉 No. It must stem from a
close family relationship recognized in law.
⚠️ DISCLAIMER:
This video is for educational purposes only and does not
guarantee complete accuracy. It was made using premium artificial
intelligence tools and should not be treated as a substitute for official
legal research.
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Ready to break down more doctrines? Let us know in the
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From <https://chatgpt.com/c/66f00b5b-5038-800a-833b-8210ab2c0454>
🎓 Welcome, future lawyers!
This short quizzer is designed to test your critical thinking and comprehension
of an important Criminal Law case decided by the Philippine Supreme
Court. This exercise is based on the landmark decision in:
📚 Case Title: People
of the Philippines vs. Raymundo Rapiz y Correa
📄 G.R. No.: 240662
📅 Date of Promulgation:
September 16, 2020
🧑⚖️ Parties: The
People of the Philippines (Plaintiff-Appellee) vs. Raymundo Rapiz y Correa
(Accused-Appellant)
⚖️ Nature of the Case: This
is a Criminal Law case involving an accusation of rape, which was
initially upheld by the Regional Trial Court and Court of Appeals. The case
reached the Supreme Court, which ultimately acquitted the accused due to
reasonable doubt, inconsistencies in the testimony of the complainant,
and lack of credible proof of threat or force.
👉 The key issue in
this case was whether a conviction for rape could be sustained based solely on
the complainant's testimony, despite its inconsistencies and questionable
credibility.
Stay with us until the end of the video—the answer key
will be provided after the quiz!
📝 QUIZ: 10 EASY
HOTS-BASED MULTIPLE CHOICE QUESTIONS
(Higher Order Thinking Skills – Designed for Bar and Law
School Training)
1. Which of the following best describes the Supreme
Court's reason for acquitting Raymundo Rapiz?
A. He proved his alibi convincingly
B. The complainant retracted her statement
C. The complainant’s testimony failed to meet the standard
of proof beyond reasonable doubt
D. He submitted evidence of a prior romantic relationship
with the complainant
2. What was the primary legal principle emphasized by
the Supreme Court in deciding the case?
A. That all rape accusations require multiple witnesses
B. That inconsistencies in testimony do not matter if the
accused is related
C. That a lone testimony must be credible and consistent to
warrant conviction
D. That physical evidence alone is always enough
3. What significant detail weakened the complainant's
claim of being threatened during the incident?
A. She said she saw the accused with another woman
B. She failed to describe or identify the alleged weapon
used to threaten her
C. She did not know the exact date of the assault
D. She had prior sexual experience
4. What behavior by the complainant raised doubts
about her lack of consent?
A. Her refusal to undergo a medical exam
B. Her voluntary outings with the accused after the incident
C. Her failure to recognize the accused in court
D. Her statements on social media
5. Why was moral ascendancy not a valid
substitute for force or intimidation in this case?
A. Because the accused was her employer
B. Because she was over 25 years old
C. Because the accused was not within the legally required
degree of relationship
D. Because she consented explicitly
6. The complainant’s failure to describe how the
accused used the alleged weapon led the Court to conclude:
A. That the accused likely used drugs instead
B. That the threat may have been fabricated
C. That she was unable to remember due to trauma
D. That the weapon was misplaced after the event
7. Which court originally convicted Raymundo Rapiz?
A. Sandiganbayan
B. Regional Trial Court
C. Court of Appeals
D. Municipal Trial Court
8. What was the complainant’s initial explanation for
continuing to meet the accused after the alleged rape?
A. He forced her to with a knife
B. She believed he was her stepfather
C. She thought he was her uncle and feared him
D. She needed financial support
9. What was the Supreme Court’s view on the lack of
immediate resistance by the complainant?
A. It is never required under any circumstance
B. It proves the rape never happened
C. It was inconsistent with her claim of threat or fear
D. It automatically indicates consent
10. The Supreme Court reiterated that in rape cases,
the credibility of the complainant:
A. Must be supported by the testimony of a family member
B. Is irrelevant if there’s medical evidence
C. Must withstand scrutiny and align with human behavior
D. Is presumed unless disproved by the defense
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