G.R. No. 229506. December 02, 2021.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SONNY ENCINAS Y SALINAS, ACCUSED-APPELLANT.

FACTS

Accused-appellant Sonny Encinas y Salinas was charged with two counts of Rape (Criminal Case Nos. 0562-2010 and 0563-2010) and one count of Lascivious Conduct (Criminal Case No. 0143-2010) against AAA, a 16-year-old minor. The prosecution’s version, based on AAA’s testimony, was that AAA, looking for work, was offered a bed space in Encinas’s house. On March 26, 2010, around 11:00 p.m., Encinas fetched AAA from work. Upon arrival, only Encinas and a renting family were in the house. After insisting they sleep in the same room, Encinas carried AAA from the bed to the floor, overpowered her resistance, removed her clothes, and had carnal knowledge of her, threatening to kill her if she reported it. A second rape occurred on March 27, 2010, around 3:00 a.m. On March 29, 2010, around 12:28 a.m., Encinas attempted to rape her again, but she resisted, ran away, and reported the incidents to the police with the help of a co-boarder. Medico-legal findings showed “Erythematous Both Labia Majora and Completely Healed Laceration at 8 o’clock Position” of AAA’s hymen. The defense, through Encinas and a witness, claimed a sweetheart defense, asserting that AAA was his girlfriend and the sexual intercourse on March 26 and 27 was consensual, and that the March 29 incident was a misunderstanding after a cellphone disturbance.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s conviction of accused-appellant Sonny Encinas y Salinas for two counts of Rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the prosecution successfully proved Encinas’s guilt for two counts of rape beyond reasonable doubt. AAA’s testimony was credible, straightforward, and consistent. The defense of consensual sexual intercourse was rejected. The Court found no ill motive for AAA to falsely accuse Encinas of such a grave crime. The medico-legal findings, though indicating a healed laceration, were consistent with AAA’s testimony of recent sexual intercourse. The sweetheart defense failed because even a previous romantic relationship does not justify non-consensual sex. The Court also noted that the defense’s attempt to attack AAA’s moral character was irrelevant. The penalty of reclusion perpetua for each count of rape, without eligibility for parole, was affirmed. The awards of civil indemnity and moral damages were also sustained. The acquittal for Lascivious Conduct was not disturbed as it was not appealed.