G.R. No. 215749. March 14, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. DANNY BANAYAT, ACCUSED-APPELLANT.

FACTS

The prosecution alleged that on November 11, 2008, at around 10:00 p.m., the victim AAA, a 16-year-old minor, went to a store to buy snacks. There, she encountered her longtime neighbor, accused-appellant Danny Banayat, who was drinking beer. Armed with a knife, Banayat forcibly dragged AAA to an abandoned house. He ordered her to remove her clothes, placed himself on top of her, and forcibly inserted his penis into her vagina repeatedly. He then threatened to kill her if she reported the incident. The following day, AAA disclosed the rape to her grandmother, leading to a barangay report and a medical examination. The medico-legal report confirmed fresh abrasions and lacerations in her genital area, consistent with recent sexual intercourse.
The defense presented a different version. A witness, storekeeper Magdalena Garcia, testified that she saw AAA at the store with a male companion, behaving amorously, and that Banayat was also present but left separately. Banayat denied raping AAA, suggesting the charge might stem from a prior misunderstanding between his uncle and AAA’s father. He argued that the prosecution failed to establish the element of force or intimidation, as AAA did not detail how the knife was used to threaten her.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Danny Banayat for the crime of rape beyond reasonable doubt.

RULING

Yes. The Supreme Court upheld the conviction, affirming the findings of the trial court and the Court of Appeals. The Court emphasized that in rape cases, the lone testimony of the victim, if credible and consistent, is sufficient for conviction. AAA’s testimony was found to be credible, natural, and consistent with human experience. The Court rejected the defense’s claim that force or intimidation was not established. AAA’s sworn statement and testimony clearly detailed that Banayat, armed with a knife, forcibly dragged her and threatened her life. Intimidation includes the moral kind, and the presence of the knife was enough to produce fear in AAA’s mind, compelling her submission. The medical findings corroborated her account of recent sexual intercourse.
The defense’s alternative narrative, suggesting AAA was with a male companion, did not undermine her credible testimony. Motive is immaterial when the crime has been positively identified by the victim. The awards for damages were modified in line with prevailing jurisprudence. Accused-appellant was sentenced to reclusion perpetua and ordered to pay AAA ₱75,000 each as civil indemnity, moral damages, and exemplary damages, with 6% interest per annum from the finality of the decision until fully paid.