GR 140001; (June, 2001) (Digest)
G.R. No. 140001; June 27, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO “EDDIE” BUENAFLOR, accused-appellant.
FACTS
On March 14, 1998, 14-year-old Lourdes Lausin was at her half-brother’s house in Lucap, Alaminos, Pangasinan. After the adults left for a dance hall, Lourdes slept on a bed in a room with six other children. Accused-appellant Eduardo Buenaflor entered, threatened to kill her if she shouted, stripped her, kissed her, mashed and sucked her breasts, licked her vagina, inserted his finger, and then his penis, performing a pumping action that culminated in the release of a hot liquid. Lourdes felt pain and cried but did not shout. Her swollen eyes were later seen by her half-brother, sister, brother, and mother, but none inquired. Buenaflor continued visiting her house to gamble. Lourdes disclosed the rape to her mother three months later, prompted partly by her sister’s revelation. A medical examination showed healed hymenal lacerations. Buenaflor was charged with rape. He was acquitted in two related rape cases by the RTC of Lingayen but was convicted in this case (Criminal Case No. 3548-A) by the RTC of Alaminos, Pangasinan, Branch 54, and sentenced to reclusion perpetua with moral damages. The trial court found Lourdes’ testimony credible, attributing inconsistencies to trauma. Buenaflor appealed, denying the accusations and claiming they all went to the dance hall together.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court REVERSED the trial court’s decision and ACQUITTED the accused-appellant. The prosecution failed to prove his guilt beyond reasonable doubt. The Court found material inconsistencies and improbabilities in the complainant’s testimony that eroded its credibility. These included her initial denial of knowing the accused, later admitting he was a neighbor and frequent visitor; the implausibility of the rape occurring without awakening six other people in the same room; and the unnatural reaction of family members who saw her swollen eyes but never asked why. The presumption of innocence must prevail, and all doubts are resolved in favor of the accused.