G.R. No. 256720 - Maibarara Geothermal, Inc. vs. Commissioner of Internal Revenue

The case involves the appellant, Petronilo Abapo, who was charged with two counts of rape committed in separate incidents under Criminal Case Nos. 133(90) and 136(90).
The offenses specifically involved allegations against two victims: Merlyn Navalon and Cherry Lyn Navalon.
The crimes were committed in Digos, Davao del Sur, Philippines, within the jurisdiction of the trial court.

Occurred in January 1989 at a residence in Bonifacio 4th, Digos.
The victim, Merlyn Navalon, was asleep when the accused allegedly approached her covertly by covering her mouth and physically assaulting her.
The accused allegedly threatened to kill her and her family members if she resisted, thereby forcing non-consensual carnal knowledge upon her.

Occurred in late September and/or early October 1989 at a house in Aplaya, Digos.
The complainant, Cherry Lyn Navalon, who was a minor of 11 years of age at the time, was allegedly subjected to force or intimidation by the accused during the incident.
The act was carried out under conditions that rendered the consent of the minor legally invalid.

Upon arraignment, the accused pleaded not guilty.
A joint trial covering both incidents was conducted, and evidence on the merits was presented.

Detailed testimonies from the victims, Merlyn and Cherry Lyn Navalon, support the occurrence of the crimes.
Medical examinations were conducted with findings indicating that the victims were no longer in a virgin state—an element consistent with the commission of the statutory rape of minors.
Documentary evidence, including birth certificates and report cards, was introduced to establish the ages and school attendance of the victims.
Testimonies from additional witnesses (including Carmenia Manliclic, the mother, and other relatives) corroborated the narrative of a violent, abusive incident.

The defense argued that the allegations were fabrications concocted by the complainants, their father Bernardo Navalon Jr., and other relatives, motivated by jealousy and vengeance.
They contended that the charges were part of a frame-up, alleging that certain physical evidence (such as a gun, bullets, and a leather bag) was planted.
The defense also raised issues on procedural grounds, claiming that the accused was illegally arrested without a warrant and that his constitutional rights were violated during the arrest process.
Additionally, the defense attempted to shift blame by alleging that the complainants had engaged in sexual relations with their elder brother, Bernardo Navalon III, thereby explaining their loss of virginity.

The trial court found that the testimonies of Merlyn and Cherry Lyn were credible despite minor inconsistencies, noting that such discrepancies are expected in spontaneous and unrehearsed testimonies.
The court gave significant weight to positive identifications made by the complainants and the supporting medical evidence.
The trial record indicated that the narrative of coercion, threats, and the physical act of rape was consistent and corroborated by multiple pieces of evidence.
The prosecution’s evidence outweighed the defense’s claims of fabrication and procedural irregularities.

Whether the trial court erred in giving credence to the testimonies of Merlyn and Cherry Lyn Navalon despite noted inconsistencies.
Whether the identification of the accused by the victims was sufficient and reliable under the circumstances.

Whether the prosecution failed to disprove the defense’s allegation that the rape charges were fabricated by the complainants’ father and other relatives.
Whether the narrative of vengeance and familial conflict could undermine the credibility of the testimonies.

Whether the arrest of the accused without a warrant and the alleged non-observation of his constitutional rights warranted reversal of the conviction.
Whether evidence obtained during the arrest, including alleged planted items (gun, bullets, leather bag), should have been excluded.

Whether the defense’s conflicting theories regarding the location and circumstances of the alleged rapes (i.e., the complainants not residing in Digos at the time versus their presence during the incidents) created sufficient doubt on the prosecution’s case.
Whether the allegations that the complainants lost their virginity through consensual relations with their elder brother had any bearing on the established crime of statutory rape.

Whether the claims of extortion by the complainants and the alleged use of force during the arrest detracted from the veracity of the evidence proving the commission of the crimes.