G.R. No. 130341 . February 10, 2000.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMMEL BALTAR, accused-appellant.

FACTS

The accused-appellant, Rommel Baltar, was convicted by the Regional Trial Court for three counts of rape committed against Kristine Karen Hugo, who was twelve years old at the time. The incidents occurred in October and November 1991 in Valenzuela, Metro Manila. Kristine testified that on each occasion, Baltar entered her home at night while she was alone, dragged her to a bedroom, threatened her with a fan knife, and had sexual intercourse with her against her will. She did not immediately report the rapes due to fear of Baltar’s threats. The crimes were only revealed in January 1992 after her mother, Adelina, witnessed Baltar pulling Kristine and subsequently took her for a medical examination. Dr. Maximo Reyes of the NBI found Kristine’s hymen to be intact but distensible, concluding it could allow penetration without laceration.
The defense presented a sweetheart theory, claiming Baltar and Kristine were lovers and that no rape occurred. Defense witnesses testified that during a confrontation, Kristine denied being raped and admitted to the relationship, which allegedly caused her mother to throw an ashtray at her. The prosecution presented Adelina in rebuttal to deny this alleged admission. The trial court found Kristine’s testimony to be clear, positive, and convincing, leading to Baltar’s conviction.

ISSUE

Whether the trial court erred in convicting the accused-appellant of three counts of rape based on the credibility of the victim’s testimony and in light of the defense’s sweetheart theory.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Kristine’s credibility, noting that her testimony was straightforward, consistent, and detailed regarding the use of force and intimidation. The medical findings, which indicated an elastic hymen capable of penetration without tearing, were consistent with her account of sexual assault. The Court rejected the defense’s sweetheart theory as inherently weak and unsubstantiated. It ruled that even if a romantic relationship existed, it does not justify or disprove rape, as a sweetheart cannot be forced to have sex against her will. The Court found the defense witnesses’ testimonies unreliable, particularly noting an inconsistency where a witness stated “nothing happened” yet also described the mother’s violent reaction upon learning of the alleged relationship.
However, the Court modified the penalty. It recognized the privileged mitigating circumstance of minority, as records showed Baltar was below eighteen years old at the time of the crimes in 1991. Applying Article 68 of the Revised Penal Code and the Indeterminate Sentence Law, the penalty was reduced. The Court also increased the civil indemnity to P75,000.00 and awarded moral damages of P50,000.00 for each count of rape. The modified sentence is imprisonment of 12 years of prision mayor as minimum to 12 years and 1 day to 20 years of reclusion temporal as maximum for each count.