Digests:

3 People v. Erquiza, G.R. No. 171348, 2008

There are 2 principles in this case. The equipoise rule, and the implied admission of
guilt.

Facts:
 Erquiza was charged of rape.

 The 13 y/o complainant narrated that on that day, or about 5pm in January 5,
2000, she was with her bestfriend Joy and her brother Ricky, in a mango
orchard.
o When her shorts got hooked to a fence, Joy and Ricky left her
allegedly. And that was the time Erquiza showed up and succeeded with
having carnal knowledge with her.
 The defense presented 2 witnesses to cast doubt that a rape happened on that
occasion:
o Joy, her bestfriend, who testified that on that day, when the complainant’s
shorts got hooked to the fence  she did not leave her, she waited for
her and thereafter, they both went home together.
o Additionally, uninterested, Juanita, a hilot, corroborated the defendant’s
alibi that he was with beside his wife, from 5pm til dawn while she was on
labor.
 The RTC and CA brushed aside the testimonies of Joy and Juanita and gave
full credence to the testimony of complainant and convicted Erquiza of Rape. 

Issue:
Did the prosecutor’s evidence pass the test of moral certainty to prove guilt
beyond reasonable doubt of the accused?

Held:
NO.

Faced with two conflicting versions, such as this case, the Court is guided by the
equipoise rule which states that
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.
More simply, the equipoise rule provides that where the evidence in a criminal case is
evenly balanced, the constitutional presumption of innocence tilts the scales in favor
of the accused.
In this case, the defense was able cast doubt as to the possibility of rape having taken
place as narrated by complainant and the testimonies of Joy and Juanita were not
satisfactorily rebutted by the prosecution, hence, the test of moral certainty is not met,
and Erquiza should not be convicted.

Offer of compromise:

 Meanwhile: The victim’s father, testified that the family of Erguiza went to their house after the case was filed, and initially
offered P50,000 and later P150,000.
 Albina, the mother of Erguiza admitted that she did talk with the parents of the victim, but, it was the spouses who asked
for P1M, later reduced to P250,000, to settle the case and that she made a counter-offer of P5,000.

2. Can the offer of compromise given by the mother of the accused be used as evidence of his guilt? 

No. For an offer compromise to amount to an implied admission of guilt, the accused should have been present or at least
authorized the proposed compromise. An offer of compromise from an unauthorized person cannot amount to an admission of the
party himself.

ITC, the parents were not authorized to offer compromise to the other party. Hence it should not be taken against him.