G.R. No. 86938 ; March 22, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANTE BANAYO, accused-appellant.

FACTS

The accused-appellant, Dante Banayo, was charged with rape before the Regional Trial Court of San Pablo City. The prosecution’s evidence established that on the evening of August 4, 1985, complainant Anselma Magampon, a waitress, was walking home alone when she was struck on the head from behind. She identified her assailant as Banayo, a customer from her workplace. After being struck again, she lost consciousness. Upon regaining her senses in a secluded area, she found her pants and panty down to her heels, with her head and genital organs bleeding. She reported to her father and was taken to the hospital. The medico-legal certificate documented physical injuries and noted her hymen was not intact, with old lacerations and fresh inflammation.
The defense presented a different narrative. Banayo claimed he and Magampon were sweethearts who had consensual sexual relations. He alleged the complaint arose after he refused her demand for marriage. He also interposed an alibi, stating he was in Barangay Palakpakin at the time of the incident. The trial court convicted Banayo of rape and sentenced him to reclusion perpetua, prompting this appeal.

ISSUE

The core issue is whether the trial court erred in giving credence to the testimony of the complainant despite alleged inconsistencies, thereby convicting the accused-appellant.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the complainant is paramount. It found that the alleged inconsistencies in Magampon’s testimony were minor and did not detract from the essential veracity of her account. Her immediate report of the assault, the physical trauma and injuries corroborated by medical findings, and her conduct of exposing herself to the ordeal of a public trial strongly indicated she was motivated by a genuine desire for justice, not by a spurned lover’s revenge as the defense suggested.
The Court rejected the defense of alibi for being weak and uncorroborated. Positive identification by the complainant, who knew the appellant as a regular customer and recognized him under illuminated conditions, prevailed over an unsubstantiated alibi. The claim of a prior romantic relationship was deemed insufficient to negate the commission of rape, as force and intimidation can still be present even in such contexts. The trial court’s assessment of witness credibility was accorded great respect. The decision was affirmed with the modification of increasing the civil indemnity to P40,000.00.