Case Summary (G.R. No. L-68298)
Incident Description
On the morning of April 4, 1982, Donna Belen was reportedly abducted and raped by an unidentified man. Initially believing him to be her uncle, confusion gave way to fear when the man physically assaulted her and coerced her into a secluded area, where he violated her at knifepoint. Following the attack, she managed to escape and sought refuge at a neighbor's house, which led her father to report the crime to authorities.
Medical Examination
Following the disclosure of the incident, a medical examination at Gumaca General Hospital confirmed that Donna had sustained injuries indicative of sexual assault, including vaginal and hymeneal lacerations, and the presence of spermatozoa in a vaginal smear was also noted. This corroborated her claims and served as key evidence in the prosecution's case against Banares.
Identification of the Suspect
Banares was apprehended on June 24, 1982, after another allegation of molestation against him surfaced, prompting Patrolman Amado Interino to revisit Donna’s earlier complaint. Donna was brought to the police station, where she successfully identified Banares from a lineup. This identification played a crucial role in establishing his culpability.
Conviction and Sentence
Subsequently, Banares was charged and convicted of forcible abduction with rape, receiving a sentence of reclusion perpetua and ordered to pay P50,000.00 in damages to the victim. The trial court’s decision was based on the gathered evidence, particularly the consistency and credibility of Donna’s testimony.
Appeal Grounds
In appealing his conviction, Banares argued that the evidence presented against him was insufficient to establish guilt beyond a reasonable doubt. He claimed inconsistencies in the testimonies of witnesses and raised objections regarding the admission of Donna's birth certificate, which was utilized to corroborate her age in accordance with the applicable provisions of the Revised Penal Code.
Court Analysis of Evidence
The court found little merit in the appellant’s arguments regarding evidentiary insufficiency or the alleged inconsistencies within the witnesses' testimonies. Contrarily, the court noted that the prosecution’s account provided a credible and coherent narrative of the events. Donna's testimony, despite her young age, was deemed clear and consistent, effectively establishing the facts of the case.
Ruling on Testimony and Evidence
The tribunal highlighted established jurisprudence that places significant weight on the testimony of a rape victim, recognizing the impossibility of fabricating such grave allegations without just cause. The court also pointed out that the lack of physical violence beyond the sexual assault itself did not diminish the gravity of the crime committed
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Case Overview
- Date: November 25, 1986
- Court: First Division, Supreme Court of the Philippines
- G.R. No.: 68298
- Plaintiff-Appellee: The People of the Philippines
- Accused-Appellant: Benjamin Banares
- Sentence: Convicted of forcible abduction with rape; sentenced to reclusion perpetua; ordered to pay P50,000 in damages.
Incident Background
- On April 4, 1982, Donna Belen, an eleven-year-old girl, reported being raped.
- Accompanied by her father and a policewoman, she identified her assailant as a man she could recognize.
- Medical examination revealed vaginal and hymeneal lacerations, confirming recent sexual intercourse and the presence of spermatozoa.
Arrest and Identification
- On June 24, 1982, Benjamin Banares was apprehended following a complaint from another girl, Eden Deduyo, alleging molestation.
- Police officer Patrolman Amado Interino had a hunch that Banares could be linked to Donna's case.
- Donna Belen identified Banares in a police line-up, confirming he was her rapist.
Trial and Conviction
- Banares was charged and convicted based on the evidence presented, which included Donna's testimony and medical findings.
- He was sentenced to reclusion perpetua and ordered to pay damages to the victim.
Evidence and Testimonies
Prosecution's Evidence:
- The prosecution's case was largely uncontr