G.R. No. 145318 -19, May 29, 2002
People of the Philippines vs. Sonny Buendia y Benjamin

FACTS

The accused-appellant, Sonny Buendia, was convicted by the Regional Trial Court of two counts of rape against Maribel Caliwag, the sister of his common-law wife, and sentenced to reclusion perpetua for each count. The prosecution alleged that in September and November 1992, Buendia, armed with a knife and using force and intimidation, sexually assaulted the complainant in their Caloocan City residence. Maribel, then sixteen years old, testified that she did not immediately report the incidents due to Buendia’s threats to kill her and her family. She finally disclosed the rapes to a classmate in March 1993, leading to Buendia’s arrest by the Bantay Bayan.
The defense presented a denial and alibi. Buendia claimed he could not have committed the crimes as he was working as a construction worker in Bulacan during the alleged periods. He asserted that the complaint was fabricated due to a family grudge stemming from his refusal to financially assist Maribel’s family and his scolding of Maribel for her relationship with a married man.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Sonny Buendia. The Court found the prosecution’s evidence insufficient to meet the required standard of proof beyond reasonable doubt. The ruling hinged on serious inconsistencies and improbabilities in the complainant’s testimony that eroded her credibility.
First, the Court found the complainant’s account of the November incident inherently incredible. She claimed she was raped inside her sister’s house while her two young nieces, aged five and three, were playing unattended in the backyard. The Court reasoned it was highly improbable that the children would not have heard any struggle or commotion, entered the house, or interrupted the act, given their very young age and proximity. The failure to account for this circumstance cast doubt on the narrative’s truthfulness.
Second, the Court noted a significant inconsistency regarding the use of a weapon. While Maribel testified during direct examination that Buendia poked a knife at her waist during the second rape, she admitted on cross-examination that he merely “showed” her the knife. This discrepancy in a crucial detail involving force and intimidation weakened the prosecution’s case.
Finally, the Court found it questionable that the complainant, who was sixteen at the time of the alleged assaults, could not provide even approximate dates for the traumatic events, stating only the months they occurred. While the exact date is not an element of the crime, the complete inability to recall any specific detail from such a harrowing experience, expected to be indelible, further undermined her credibility. Consequently, the totality of these deficiencies created reasonable doubt, warranting acquittal.