G.R. No. 140001 - People vs. Buenaflor

On March 14, 1998, a sexual assault allegedly occurred in Lucap, Alaminos, Pangasinan.
The complainant, Lourdes Lausin, then 14 years old, was staying at the house of her half-brother, Arman Abella, during a fiesta.
The accused, Eduardo “Eddie” Buenaflor, was present in the household and was seen cooking upon Lourdes’ arrival.

After dinner, while the household’s adult members left for a dance hall, Lourdes and three other children (her sister Flordeluna, brother Ricky, and the Abella children) stayed behind in the only bedroom.
While all the children were sleeping, Buenaflor allegedly entered the room and, without arousing the attention of the others, sat on the edge of Lourdes’ bed.
According to Lourdes’ testimony, Buenaflor threatened her with death should she attempt to call out, which inhibited her from resisting.
The accused proceeded to strip her of her jeans, T-shirt, bra, and panties, and conducted a series of sexual acts that included kissing, fondling her breasts, and ultimately inserting his finger and later his penis into her vagina.

The victim described feeling pain throughout the ordeal but noted that her pain was not so intense as to cause her to shout due to the alleged threat.
Despite her distress, she cried, resulting in visibly swollen eyes which were noticed by others in the household including her siblings, the Abella couple, and later by her mother.
Although some physical evidence was later obtained (a Medico-Legal Certificate revealing healed hymenal lacerations at specific positions), there were inconsistencies in the victim’s narrative regarding the identity and familiarity of the accused.

Post-incident, Buenaflor continued to visit the complainant’s house regularly to play card games, a practice he had maintained previously.
It was not until June 26, 1998—three months after the incident—that Lourdes disclosed the details of the alleged rape to her mother, a delay partly attributed to revelations by her sister, Flordeluna.
The prosecution charged Buenaflor in the Regional Trial Court (RTC) of Alaminos, Pangasinan, Branch 54, under Criminal Case No. 3548-A for rape as defined under Article 335 of the Revised Penal Code as amended by R.A. 7659.
In addition to this case, two other criminal cases (Criminal Case Nos. L-5894 and L-5895) for alleged rape were filed in the RTC in Lingayen, although in one instance the accused was acquitted.
The RTC at Alaminos, however, found Buenaflor guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and awarded moral damages amounting to P50,000.00 to the offended party.

The complainant’s account was marked by internal inconsistencies, including contradictory statements regarding whether she was alone or accompanied by siblings during the incident.
Initially, she testified that she did not know Buenaflor prior to the rape; however, during cross-examination she admitted that he was known to her as a frequent visitor who came to gamble at her house.
Her recollections regarding the physical events—such as the removal of her clothing, the sequence of sexual acts, and her subdued reaction in spite of apparent pain—were interspersed with gaps and uncertainties.
The trial court attributed some inconsistencies to the trauma and the defensive response of a young rape victim, a rationale that later became a point of contention on appeal.

The accused contended that the trial court erred in convicting him despite the lack of credible, consistent, and reliable testimony regarding the rape.
He argued that the court improperly gave full credence to the complainant’s testimony while discounting defense evidence and witness testimonies.
The defense further questioned the interpretation of the alleged trauma, challenging the assumption that the victim’s inconsistencies were necessarily due to fear or shock.
Additionally, it was contended that the court misinterpreted the significance of the sworn statement submitted by the complainant, which the accused claimed did not amount to an implied admission of guilt.

The Supreme Court reviewed the inconsistencies in the complainant’s testimony, noting several contradictions regarding her account of the events, her familiarity with the accused, and the absence of corroborative testimony from other household members (such as Arman Abella).
The Court emphasized that in rape cases the complainant’s credibility is paramount; however, in this instance, her testimony was riddled with improbabilities that could not be reconciled even when considering the impact of trauma.
The Court also found fault in the trial court’s reliance on the victim’s narrative while simultaneously neglecting defense evidence which raised substantial doubt.
As a result, the Supreme Court ruled that the prosecution had not met the requisite burden of proving the accused’s guilt beyond reasonable doubt.

Whether the trial court correctly convicted the accused despite significant inconsistencies and contradictions in the complainant’s testimony.
Whether the prosecution was able to establish the accused’s guilt beyond reasonable doubt in light of the conflicting witness accounts and evidentiary deficiencies.
Whether the trial court erred in attributing the inconsistencies in the complainant’s narrative solely to the trauma and intimidation she allegedly experienced.
Whether acceptance of the sworn statement offered by the accused as part of his defense amounts to an implicit admission of guilt by the accused.
Whether the trial court improperly weighted the evidence in deciding to sentence the accused to reclusion perpetua and award moral damages.