G.R. No. L-68298 November 25, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN BAÑARES, accused-appellant.

FACTS

In the early morning of April 4, 1982, eleven-year-old Donna Belen awoke to find herself being carried by a man away from her home in Gumaca, Quezon. The man deceived her, claiming he was taking her to her parents. Upon realizing they had passed the stated destination, Donna became fearful. When she cried out, the man punched her and threatened her with a knife. He then led her to a grassy area where, at knifepoint, he forced her to undress and raped her. During the assault, a flashlight illuminated the man’s face, allowing Donna to see him clearly. She later escaped and reported the incident to the authorities. A medical examination confirmed recent sexual intercourse and physical injuries consistent with rape.
More than two months later, on June 24, 1982, accused-appellant Benjamin Bañares was apprehended on an unrelated complaint of molestation. Recalling Donna’s case, police fetched her for a line-up. Donna positively identified Bañares as her assailant from a group of four men. He was subsequently charged with forcible abduction with rape. The trial court convicted Bañares and sentenced him to reclusion perpetua, with damages. He appealed, contesting the sufficiency of evidence and credibility of witnesses.

ISSUE

Whether the prosecution evidence, particularly the testimony of the victim and her out-of-court identification, is sufficient to prove the guilt of the accused beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the victim, Donna Belen, to be remarkably clear, coherent, and credible despite her tender age and rigorous cross-examination. Her detailed account of the abduction, the threat and use of a knife, the rape, and her escape formed a consistent narrative. The medical findings corroborated her claim of recent sexual violation. The Court emphasized that the absence of extensive physical injuries, other than the vaginal laceration, did not negate rape; it only proved she submitted out of fear for her life at knifepoint, which constitutes intimidation.
Regarding the identification, the Court held it was reliable. Donna had a clear view of her attacker’s face during the crime when a flashlight illuminated him. Her identification of Bañares from a police line-up over two months later was spontaneous and unequivocal. In contrast, the defense of bare denial offered by Bañares was feeble and uncorroborated. He failed to provide an alibi or produce witnesses, such as the alleged intermediary who offered money for the complaint’s withdrawal, to substantiate his claims. The trial court’s assessment of witness credibility is accorded great respect, and no compelling reason existed to overturn its findings. The alleged inconsistencies in prosecution testimony were minor and did not affect the core facts of the crime. The conviction was therefore upheld.