G.R. No. 132368 January 20, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PACITO GARCES JR., accused-appellant.

FACTS

The prosecution alleged that on May 14, 1995, in Jimalalud, Negros Oriental, appellant Pacito Garces Jr. barged into the house of Rosalie Ganaganag while she was alone. He embraced her, poked a knife at her chest, forced her to lie down, and had carnal knowledge of her against her will. After the act, he threatened to kill her and her family if she reported the incident. Rosalie immediately reported the rape to her neighbor, Pacita Garces, and Barangay Councilor Wilson Garces, who noted her disheveled hair and physical injuries. She was medically examined on the same day, with findings of hymenal lacerations and the presence of spermatozoa.
The defense, however, presented a different version. Appellant claimed that he and Rosalie were sweethearts and that the sexual intercourse on that day was consensual, arising from their romantic relationship. He asserted that Rosalie threatened to file a rape case if he did not marry her. The defense presented a witness, Porferio Paculang, who testified that he often saw the two together and that appellant had told him they were engaged.

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 testimony of the victim, Rosalie Ganaganag, to be credible, straightforward, and consistent. Her immediate reporting of the incident to neighbors and barangay officials, coupled with her distraught condition and the physical signs noted by them, lent strong corroboration to her account. The medicolegal findings, which confirmed recent sexual intercourse and hymenal lacerations, provided objective support for her claim of forcible defloration.
The Court rejected the appellant’s “sweetheart defense” as unsubstantiated. It ruled that such a defense requires proof, such as love letters, photographs, or other mementos, which were entirely absent. The bare assertion of a romantic relationship, supported only by the doubtful testimony of a single witness, could not prevail over the positive and credible identification by the victim. The Court emphasized that even if a relationship were proven, it does not equate to consent for each sexual act, as “love is not a license for lust.” The force and intimidation employed by the appellant, including the use of a knife, were sufficiently established. The decision of the Regional Trial Court was affirmed with modification, increasing the award of moral damages to P50,000.00 and awarding exemplary damages of P25,000.00.