GR 135699; (October, 2000) (Digest)
G.R. No. 135699-700, 139103; October 19, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CESAR CLADO, accused-appellant.
FACTS
Accused-appellant Cesar Clado was charged with three counts of rape allegedly committed on April 14 and 15, 1997, against Salve Cariño, a 15-year-old. The prosecution evidence established that on the evening of April 14, Clado forced his way into the beauty parlor where Salve was tending shop, switched off the lights, threatened to kill her, and raped her. The following night, he returned, again forced entry, and raped her twice. Salve revealed the incidents to her sister days later, leading to a medical examination which confirmed loss of physical virginity with healed hymenal lacerations.
The defense presented a sweetheart theory, claiming the sexual acts were consensual. Clado testified that he and Salve were lovers and that she actively participated. He suggested her motive for filing charges was his decision to end the relationship upon discovering she was not a virgin.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that Clado committed rape through force and intimidation, thereby overcoming his defense of a consensual romantic relationship.
RULING
The Supreme Court affirmed the conviction for two counts of rape. The Court found the testimony of the private complainant credible, straightforward, and consistent. It emphasized that when a victim’s testimony passes the test of credibility, it is sufficient to sustain a conviction for rape. The Court rejected the sweetheart defense as a fabrication, noting the complete absence of corroborative evidence such as love notes or mementos to substantiate the claim of a romantic relationship, which had allegedly lasted only a week. The medical findings, while not conclusive of force, were consistent with her narrative.
The legal logic hinges on the principle that an accusation of rape is difficult to make, especially for a young barrio lass, and is thus accorded credence when narrated without ulterior motive. The defense failed to meet its burden of proof to substantiate its claim of consent. Consequently, the trial court’s judgment was upheld, including the award of civil indemnity. Pursuant to prevailing jurisprudence, the Court additionally awarded moral damages for each count.