G.R. No. 124975 ; February 20, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FLORIANO AMAQUIN y LASTIMADO, accused-appellant.

FACTS

The prosecution’s evidence established that on an afternoon in October 1993, 13-year-old Jonah Flores was walking home from school in Davao City when the accused, Floriano Amaquin, suddenly pulled her into a banana plantation. He poked a gun at her, threatened her, and then forcibly had carnal knowledge of her. Afterward, he warned her not to tell anyone. Jonah eventually reported the incident to her parents in early November, leading to a medical examination which revealed healed hymenal lacerations consistent with sexual intercourse.
The defense presented a different narrative, invoking the “sweetheart theory.” Amaquin, who was married and known to Jonah’s family, claimed they were in a romantic relationship. He alleged that Jonah would ride in his jeepney, that her parents knew of their closeness, and that he had given her money. He denied raping her and suggested the charge was filed after a quarrel when he accused her of being only after his money.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Amaquin committed rape, or if his defense of a consensual romantic relationship is credible.

RULING

The Supreme Court affirmed the conviction. The Court found the victim’s testimony to be clear, credible, and consistent. At 13 years old, her detailed account of the assault, including the use of a gun and threats, was straightforward and unshaken by cross-examination. The medical findings corroborated her claim of sexual violation. The Court emphasized that the “sweetheart defense” is a common but weak ploy in rape cases, often used to impugn the victim’s character. For such a defense to succeed, it must be substantiated by strong and convincing evidence.
Here, Amaquin’s claim was not only uncorroborated but was also inherently improbable. His assertion of a public courtship with a minor, allegedly with parental knowledge, was belied by the natural reaction of the victim’s parents who immediately acted upon her revelation. The defense failed to provide any credible proof of this alleged relationship. The Court ruled that the trial court correctly gave full weight to the victim’s positive identification and credible testimony over the accused’s bare denial and implausible story. The conviction for rape under Article 335 of the Revised Penal Code was upheld, and the civil indemnity was increased to Fifty Thousand Pesos (₱50,000.00), with an additional Fifty Thousand Pesos (₱50,000.00) as moral damages.