GR 126026; (February, 2001) (Digest)
G.R. No. 126026 . February 6, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAURICIO LOYOLA y BOTAYA alias “JUNIOR”, accused-appellant.
FACTS
The prosecution established that on April 11, 1994, sixteen-year-old Stecy Gatilogo boarded a bus in Pangantucan, Bukidnon. The bus conductor, accused-appellant Mauricio Loyola, took a special interest in her, sat beside her, and struck up a conversation. Due to impassable roads, the bus returned to Kalilangan. After dinner, Stecy slept on a bus seat. At midnight, she was awakened by someone touching her breast; she recognized Loyola’s voice. He threatened to kill her if she shouted. With one arm trapped in a seat gap, Stecy could not effectively resist. Loyola forcibly removed her pants and underwear and had carnal knowledge of her against her will.
The defense interposed the “sweetheart defense,” claiming Stecy was his lover and their sexual intercourse was consensual. He alleged they had met and courted prior to the incident. After the act, he offered marriage, which Stecy refused, stating he was not her sweetheart. The Regional Trial Court convicted Loyola of rape and sentenced him to reclusion perpetua and an indemnity of P30,000.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
Yes. The Supreme Court affirmed the conviction. The Court found the victim’s testimony credible, straightforward, and consistent. It detailed how the accused used force and intimidation, exploiting her trapped arm and threatening her life to accomplish his lewd design. The medical certificate, indicating a broken hymen, corroborated her claim of sexual intercourse. The Court rejected the sweetheart defense for lack of credible proof. The defense failed to substantiate the alleged romantic relationship with convincing evidence. The Court emphasized that an offer of marriage is typically an admission of guilt in rape cases, and Stecy’s rejection of it bolstered her lack of consent. The positive identification by the victim prevails over the accused’s bare denial. The award of civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence. Furthermore, moral damages in the amount of P50,000.00 were awarded without need of further proof, as recognized in rape cases for the victim’s trauma and suffering.