G.R. No. 136003-04 October 17, 2000
The People of the Philippines, plaintiff-appellee, vs. Pablito Adajio y Adaya, accused-appellant.

FACTS

Accused-appellant Pablito Adajio was convicted by the Regional Trial Court of two counts of rape against his wife’s 13-year-old niece, Melanie Manalo. The separate Informations alleged that on May 4 and June 19, 1994, in Sta. Teresita, Batangas, Adajio, armed with a bolo, had carnal knowledge of Melanie through force and intimidation. The victim testified that on both occasions, Adajio, wielding a bolo, brought her to an isolated area, threatened her, and forcibly had sexual intercourse with her. She resisted and felt pain, and Adajio warned her not to report the incidents.
The defense interposed the “sweetheart theory,” claiming the sexual acts were consensual as he and Melanie were lovers. As proof, he presented an ID picture she gave him, alleged jail visits, and a signed ten-peso bill. The trial court rejected this defense, found Melanie’s testimony credible, and sentenced Adajio to reclusion perpetua for each count with corresponding civil indemnity.

ISSUE

Whether the trial court erred in convicting accused-appellant of two counts of rape by giving full credence to the prosecution’s evidence and rejecting the “sweetheart” defense.

RULING

The Supreme Court affirmed the conviction. The core issue is factual and hinges on witness credibility, where the trial court’s assessment is accorded high respect. The Court found no reason to deviate from this rule, as the trial judge directly observed the witnesses’ demeanor. Melanie’s detailed and consistent testimony on the use of a bolo, the force employed, her resistance, and the subsequent threats established the elements of rape through intimidation. Her young age and relationship to the appellant as a niece by affinity made her vulnerable and bolstered her credibility.
The “sweetheart theory” was properly rejected. The alleged tokens of affection were trivial and did not convincingly prove a romantic relationship, especially when weighed against the clear and positive testimony of rape. The Court noted that a victim’s delay in reporting, often due to threats, does not undermine credibility. The proximity of Adajio’s residence to the victim’s after the first incident did not indicate innocence but provided the opportunity for the second rape. The penalty of reclusion perpetua for each count was affirmed, being the proper penalty for rape committed with a deadly weapon absent aggravating circumstances. The Court modified the damages, ordering an additional P50,000.00 as moral damages for each count, in line with prevailing jurisprudence.