G.R. No. 135231 -33, February 28, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BLESIE VELASCO, accused-appellant.

FACTS

Accused-appellant Blesie Velasco, the stepfather of twelve-year-old Raquel Yasas, was charged with three counts of rape. The prosecution evidence established that the rapes occurred on December 29, 1996, January 7, 1997, and January 17, 1997. Raquel testified that on each occasion, Velasco used intimidation, threats with a firearm or knife, and physical force to coerce her into sexual intercourse. He threatened to kill her and her family if she reported the assaults. Raquel eventually escaped and reported the crimes to a social worker. A medico-legal examination confirmed she was in a non-virgin state, with healed hymenal lacerations.
The defense presented a radically different narrative, invoking the “sweetheart theory.” Velasco claimed he and Raquel were in a consensual romantic relationship, alleging she initiated their sexual encounters out of jealousy over his relationship with another woman. He asserted the charges were fabricated after Raquel’s mother discovered their affair. The trial court rejected this defense, found Velasco guilty of three counts of rape, and imposed the death penalty, prompting this automatic review.

ISSUE

The core issue is whether the prosecution proved Velasco’s guilt for the crime of rape beyond reasonable doubt, and whether the “sweetheart theory” defense is credible.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the credibility of the victim’s testimony against the incredibility of the defense. In rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. Raquel’s detailed, consistent, and candid narration of the three traumatic incidents, including the specific threats and use of weapons, was found to be credible and compelling. The Court noted her young age and the natural inconsistency in minor details, which instead bolstered her truthfulness.
The defense’s “sweetheart theory” was unanimously rejected as preposterous and contrary to human nature and experience. The Court found it inconceivable that a twelve-year-old girl would fabricate a story of multiple rapes by her stepfather, a person in a position of moral authority, out of mere jealousy. This theory was deemed a desperate and transparent attempt to evade liability. The relationship of stepfather-stepdaughter, characterized by moral ascendancy, rendered the use of force or intimidation unnecessary to establish carnal knowledge. The presence of intimidation was sufficiently proven by Raquel’s fear of Velasco’s threats and weapons. The death penalty was affirmed, with the Court finding no mitigating circumstances to warrant a lesser penalty.