G.R. No. L-4948 - El Juez de Primera Instancia De Baguio vs. Valles

The complainant, Lucila Buenafe, was a thirteen-year-old girl living in Gapas, Guinayangan, Quezon with her family.
Appellant Mario Andal, then in his twenty-fifth year, resided immediately adjoining the Buenafe household, while his father, Isidro Andal, was sixty-three years old.

At noontime, both appellants visited the Buenafe residence with the initial purpose of retrieving a pig and a sprayer.

They were informed that the pig had been taken to Calauag, Quezon and the sprayer was already borrowed by another person.
The unsatisfactory response allegedly displeased the appellants.

Following this initial interaction, Mario Andal proceeded upstairs and ordered Lucila and her brother to open a trunk, though nothing was taken at that time.

The situation escalated when the appellants forcibly dragged the complainant to a nearby hill.

Upon reaching the hill, the victim was pushed to the ground.
Mario Andal initiated the assault by disrobing the complainant and, due to her resistance, struck her on the chest and later used his knees to keep her legs apart.
A subsequent blow on her abdomen rendered the complainant unconscious, thus facilitating the consummation of the rape.

Isidro Andal, the father, actively assisted in the commission of the crime by restraining the victim’s hands, thereby preventing her from resisting further.

Upon regaining consciousness, the complainant discovered that both appellants had already fled the scene.
Still experiencing pain and feeling faint, she sought help by going to Calauag, Quezon where her father was working.
The complainant reported the incident to a policeman in a warehouse at Zamora Street, leading to immediate referral and instruction to report the crime in Guinayangan, Quezon—the actual location of the incident.
A medical examination was conducted by Dr. Gaspar E. Villafane at Magsaysay Memorial Hospital, which documented:

A contusion at the upper left chest (suggesting a fist blow).
Scratches on the left thigh and buttocks, possibly inflicted by a pointed object.
Fresh lacerations across the hymen at multiple clock positions, consistent with the penetration by a hard object.

The extent of the injuries required the complainant’s hospitalization for one week.

The sequence of events was supported by the victim’s testimony, despite attempts by the defense to highlight inconsistencies between her affidavit and her courtroom account.
Multiple instances during her testimony revealed her emotional distress:

Her tears and visible apprehension were noted when she identified the appellants.
Observations by Dr. Villafane and a confirming policeman underscored her distress and the painful recollections of the crime.

The medical findings provided objective corroboration of the physical injuries inflicted during the rape.

The trial court, after considering all evidence—including the physical, testimonial, and circumstantial—the facts established guilt beyond reasonable doubt.
Both appellants were convicted of rape, with Isidro Andal’s involvement characterized as that of an accomplice due to his direct role in restraining the victim.

Whether the constitutional principle that the accused shall be presumed innocent until proven guilty beyond reasonable doubt was violated by the prosecution’s approach.
Whether the defense’s argument, based on alleged inconsistencies in the victim’s testimony, effectively undermined the necessary proof of guilt.

The weight and credibility of the victim’s testimony in light of her emotional state and the corroborative medical examination.
The impact of the defense’s reliance on the constitutional presumption of innocence versus the overwhelming physical and testimonial evidence presented.

The extent to which Mario Andal’s direct commission of the rape establishes his full criminal liability.
Whether Isidro Andal’s active participation as an accomplice, by restraining the victim, warrants the same level of criminal responsibility.

The evidentiary value of the medical findings in substantiating the occurrence and the particulars of the sexual abuse.
How the objective medical testimony validates the victim’s account against any claims of inconsistency by the defense.