G.R. No. 207990 - People vs. Buenvinoto y Paglinawan

The case involves the People of the Philippines charging Elias Buenvinoto y Paglinawan with four counts of rape.
The victim, designated as AAA, was a 13‑year‑old girl who, during her infancy, was verbally adopted by the accused-appellant and his common‑law wife despite the lack of formal court proceedings.
AAA’s biological family circumstances are relevant: her mother (BBB) abandoned the family, leaving her and her siblings under the care of their father (CCC), a shoemaker, who later entrusted AAA to the accused-appellant.

June 14, 2004 – At around 11:00 a.m. in Barangay Sabang, San Jose, Camarines Sur.
July 7, 2004 – At around 2:00 p.m. while AAA was engaged in daily chores at home.
August 18, 2004 – At around 10:00 a.m. while AAA was working on school assignments.
September 13, 2004 – At around 3:00 a.m. in the household of the accused.

In each incident, the accused is alleged to have utilized force, threats involving a knife, and other means of intimidation:

During the first incident, the accused-appellant reportedly poked a knife at AAA’s neck, dragged her into a room, undressed her, and forcibly penetrated her.
In the second incident, he is alleged to have dragged her at knifepoint, undressed her, placed a cloth in her mouth, coerced her into lying down, and again forcibly committed the act.
The third incident involved the accused-appellant tearing apart her dress as she was pleading for him to stop, yet he continued with his act.
In the fourth incident, he is alleged to have removed her short pants and underwear before performing the act without observable physical abuse that would leave visible marks.

AAA provided a detailed and emotionally charged narration of the events, describing fear, physical abuse (kicks, slapping, use of a knife), and forced penetration.
CCC, the biological father of AAA, confirmed her verbal adoption and emphasized the lack of proper legal adoption procedures.
Dr. Jane Perpetua Fajardo, the medicolegal officer, performed a genital examination:

Despite AAA’s intact hymen, it was noted to be distensible—extending to more than 2.5 centimeters—indicating that sexual intercourse could have occurred without causing laceration.
The measured hymenal orifice of 3 centimeters supported the possibility of complete penetration by an average‑sized adult male.

Police witness PO1 Fara M. Bolong corroborated the existence of a police blotter filed by AAA accompanied by public health and local government officials.

He pleaded not guilty and claimed that he was alone at home during the incidents.
He attempted to offer an alibi for each incident by stating that he was either fishing or repairing fishing nets at the relevant times.
He alleged that delays in the filing of the complaint were aimed at discrediting him and asserted that the victim’s physical condition (such as an intact hymen) indicated arousal rather than resistance.

Held a joint trial with testimonies from AAA, CCC, Dr. Fajardo, and PO1 Bolong.
On August 25, 2009, the RTC convicted the accused-appellant of four counts of simple rape, imposing reclusion perpetua for each count.
The RTC awarded damages to AAA: P75,000.00 as civil indemnity, P50,000.00 as moral damages, and P25,000.00 as exemplary damages per count.
The award of confinement credits was addressed subject to the accused’s compliance with the prescribed rules.

On June 1, 2012, the CA affirmed in toto the RTC’s decision.
The CA emphasized the consistent and straightforward testimony of AAA and noted the credibility of the witnesses.
The CA rebutted the defenses on alibi and denial, and maintained that the physical evidence (or lack thereof, specifically regarding hymenal laceration) did not negate the occurrence of rape.

Whether the testimony of AAA and corroborative medical evidence were sufficient to prove beyond reasonable doubt that the accused-appellant had raped AAA on all four separate occasions.
Whether the lack of visible hymenal laceration could be taken as evidence against the occurrence of rape, considering the nature of the victim’s physiology.

Whether AAA’s delay in reporting the criminal incidences affected the credibility of her testimony.
Whether the inherent vulnerability and psychological trauma of a 13‑year‑old victim could explain the delay and hesitancy in immediately reporting the abuse.

Whether the accused-appellant’s defenses of denial and alibi, as well as his assertions concerning the victim’s alleged arousal during intercourse, are credible and sufficient to create reasonable doubt.
Whether the absence of physical injuries sufficiently undermined the victim’s account of the crime.

Whether the special qualifying circumstance (the alleged stepfather relationship) was adequately proven given that AAA was only verbally adopted and such relationship was not substantiated by formal legal proceedings.