G.R. No. L-68298 - People vs. Banares

On the morning of April 4, 1982, Donna Belen, an 11-year-old girl from Barangay Buensoceso, Gumaca, Quezon, reported that she had been raped.
She was accompanied to the police station by her father and a neighbor, Fe Tarasona, a policewoman, who helped facilitate the filing of the report.

Donna Belen was immediately taken to Gumaca General Hospital, where a medical examination revealed vaginal and hymeneal lacerations and confirmed that she had recently lost her virginity.
A vaginal smear test conducted on the victim detected the presence of spermatozoa, reinforcing the medical findings.

More than two months later, on June 24, 1982, a different complaint was filed by Eden Deduyo, alleging that Benjamin Banares had molested her by taking her to a movie house and touching her private parts.
Acting on a hunch that Banares might be involved in Donna Belen’s earlier case, Patrolman Amado Interino brought the girl and her father to the police station, where she identified Banares from a lineup of four men.

The victim was asleep at the family house when she awoke to find herself being carried by a man whom she initially believed to be her uncle.
The man led her away from home, claiming he was taking her to the house of an “Aling Lorna” where her parents were, but deviated from the expected route.
When Donna Belen asked to attend to a call of nature, the man refused her request; during this time, he placed his hand on her waist, causing her to cry out.
The man punched her in the face and threatened further harm if she continued to resist, thereby intensifying her fear.
The perpetrator then forced the girl to undress, laid himself on top of her, and raped her at knife-point, using a flashlight placed atop their clothes which allowed Donna an unmistakable look at his face for the first time.
Even after Donna Belen dressed, the man ordered her to disrobe again; the resulting distraction, due to an external noise, enabled her to escape and seek refuge at the home of Elizabeth Lagarile, located about fifty meters away.

After seeking refuge, Donna Belen was taken by Elizabeth Lagarile to her own home and, later, to the police station where her father assisted in reporting the incident.
In further developments, about five months post-incident, Teodulo Buena approached Donna’s parents with an offer of P1,000.00 to withdraw the complaint, which Donna decisively refused.

Benjamin Banares was apprehended on June 24, 1982, subsequent to corroborative complaints, including the one from Eden Deduyo.
He was charged with forcible abduction with rape. The trial courts found the evidence—comprising the victim’s consistent narrative, medical examinations, and credible identification—to be sufficient to convict him, leading to his sentencing.

The prosecution’s evidence was largely uncontradicted apart from the defendant’s bare denials. The testimonies and medical findings collectively provided a coherent and credible account of the rape.
The defense’s unsubstantiated denial did not include any evidence or alibi regarding his whereabouts at the time of the crime.
An unauthenticated copy of Donna Belen’s birth certificate was admitted to establish her age, a measure aimed to justify the application of specific articles of the Revised Penal Code, despite later challenges regarding its admissibility.

Whether the evidence, including the victim’s testimony and physical findings, is sufficiently reliable to prove beyond a reasonable doubt that Benjamin Banares committed the crime.
Consideration of the coherence and consistency of the eyewitness testimonies in light of the trauma experienced by the victim.

The reliability of Donna Belen’s account, given her tender age and the emotional strain associated with her ordeal.
Whether any inconsistencies in the testimonies of the prosecution witnesses could undermine the integrity of the victim’s detailed narrative.

The propriety of admitting an unauthenticated copy of the victim’s birth certificate to establish her age.
The impact of failing to challenge the birth certificate’s admissibility at the time it was introduced, on appeal.

Whether the bare denials offered by Benjamin Banares, without any corroborating evidence or alibi, suffice as a defense.
The significance of the defense’s failure to displace the presumption established by the victim’s testimony and the circumstantial evidence.