G.R. No. 128157 September 29, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL MANAHAN, alias “Maning,” defendant-appellant.

FACTS

Complainant Teresita Tibigar, a 16-year-old stay-in waitress at the Espiritu Canteen in Dagupan City, was asleep on the second floor of the canteen on January 5, 1995, at about 2:00 a.m. She was awakened when she felt someone beside her and saw the accused, Manuel Manahan, who was the brother-in-law of the canteen owner. He immediately placed himself on top of her, covered her mouth when she tried to shout, and forcibly spread her legs. She cried, pushed, and kicked him repeatedly but eventually became weary and exhausted, enabling the accused to lift her skirt, remove her panty, and insert his penis into her vagina. After satisfying his lust, he threatened to kill her and her family if she reported the incident. The sexual encounter resulted in her pregnancy, and she gave birth to a baby girl on October 2, 1995. She later filed a criminal complaint for rape. The accused denied the charge, claiming they were lovers and that their sexual intercourse was consensual, occurring on several occasions starting December 27, 1994. The trial court found him guilty of rape and sentenced him to death.

ISSUE

Whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly in light of his defense of a “sweetheart theory” and the alleged absence of force and intimidation.

RULING

The Supreme Court sustained the conviction. The trial court’s findings on the credibility of witnesses are entitled to the highest respect and were not shown to be overlooked, misunderstood, or misapplied. The accused’s “sweetheart theory” failed as it was categorically denied by the victim and was unsupported by substantial evidence like love notes or mementos. The testimonies of defense witnesses did not conclusively prove an amorous relationship, and one witness’s testimony was disregarded by the trial court for lack of seriousness. Even assuming a romantic liaison existed, it does not negate rape, as a sweetheart cannot be forced to have sex against her will. The element of force was established beyond doubt through the victim’s clear and convincing testimony detailing how she resisted by pushing and kicking but was overpowered by the accused’s strength. The penalty imposed by the trial court was in accordance with law, as the crime was committed with the use of force.