GR 140278; (June, 2004) (Digest)
G.R. No. 140278 ; June 3, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. SONNY BAUTISTA y LACANILAO, appellant.
FACTS
The prosecution’s evidence established that on March 8, 1996, appellant Sonny Bautista, a family friend and godchild by marriage of the victim’s parents, convinced 15-year-old Mischel Amparo to skip her classes under the pretext of joining a field trip with his wife. Instead, he brought her to a movie and then to the Town and Country Motel. Inside the motel room, appellant forced Mischel to take a bath, carried her to the bed, and kissed her. Despite her fierce resistance, which included slapping him, appellant overpowered her by punching her thighs, removed her clothes, and succeeded in having carnal knowledge against her will. The victim reported the incident, and a medical examination confirmed recent sexual intercourse.
The defense interposed the “sweetheart” theory, claiming that he and the victim were lovers and that their sexual encounter in the motel was consensual. He asserted that the relationship began when they were co-tenants in her parents’ house and that they had engaged in sexual intercourse on several prior occasions. He alleged that the charge was fabricated by the victim’s mother due to a personal grudge.
ISSUE
Whether the Court of Appeals erred in affirming appellant’s conviction for rape, despite his claim of a consensual sexual relationship with the victim.
RULING
The Supreme Court affirmed the conviction. The Court held that the “sweetheart” defense requires compelling proof of two elements: first, that the accused and the victim were indeed lovers, and second, that the victim consented to the specific sexual act in question. The Court found the appellant’s evidence for the alleged romantic relationship to be weak, self-serving, and uncorroborated. His testimony was inconsistent and failed to provide credible details about the supposed courtship. In contrast, the victim’s testimony was clear, consistent, and credible, detailing the force, intimidation, and lack of consent. The Court emphasized that love is not a license for lust, and a prior relationship does not justify or presume consent to a subsequent act. The medical findings, the victim’s prompt reporting, and her straightforward narration of the traumatic event corroborated the commission of rape. The defense of consensual sex, being inherently weak, must be established by strong evidence, which the appellant utterly failed to do. Thus, his guilt was proven beyond reasonable doubt.