G.R. No. 47628. May 15, 1989.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO MANCILLA, accused-appellant.

FACTS

The prosecution alleged that on November 28, 1974, accused-appellant Reynaldo Mancilla, a 26-year-old driver for a bishop, fetched Rosita Sabuero and her 17-year-old niece, complainant Susan Sabuero. Upon reaching their destination, Rosita alighted, but Mancilla sped away with Susan. He drove to a secluded area, threatened her with a dagger, and forcibly had carnal knowledge of her despite her resistance. Afterward, he warned her not to tell anyone. Susan immediately reported the incident to her family, underwent a medical examination which revealed fresh hymenal lacerations and semen, and filed a complaint. Mancilla was convicted of rape and sentenced to reclusion perpetua.
The defense interposed the sweetheart theory. Mancilla claimed he and Susan were lovers who had mutually consented to sexual intercourse. He testified that he courted and was accepted by Susan within a remarkably short period, even boasting about his prowess in quickly winning the affections of other women. He asserted their encounter was consensual and occurred in the jeep at a secluded spot chosen by Susan for privacy.

ISSUE

Whether the accused-appellant’s conviction for the crime of rape is proper, considering his defense of a consensual sexual relationship.

RULING

The Supreme Court affirmed the conviction. The Court found the accused-appellant’s defense of a consensual sweetheart relationship utterly incredible and unsupported by evidence. His self-serving testimony about his rapid courtship success was deemed a fantastic tale that did not outweigh the clear and credible narrative of the complainant. The Court emphasized that no corroborating evidence was presented to prove any romantic relationship, especially since the parties had met only the day before the incident, and Susan’s teacher contradicted Mancilla’s alibi for that prior day.
The Court gave full credence to Susan’s consistent and straightforward account of the rape, which was corroborated by the immediate medical findings of fresh lacerations and the presence of semen. Her prompt reporting to authorities and submission to an examination were deemed consistent with the conduct of a victim, not a consenting partner. The lack of external physical injuries did not negate rape, as the threat with a dagger sufficiently established intimidation and force. The unexplained conduct of Rosita, who did not immediately seek help, was considered irrelevant to Susan’s own credibility. The prosecution successfully proved the elements of rape beyond reasonable doubt.