GR 47628; (May, 1989) (Digest)
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, fetched Rosita Sabuero and her 17-year-old niece, complainant Susan Sabuero. Upon arrival at 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 with 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 they met only the day before the incident, but he successfully courted her, and she agreed to have sex in the jeep. To bolster his credibility, he boasted of his prowess, claiming other women had accepted his advances within minutes or days.
ISSUE
Whether the accused-appellant’s conviction for the crime of rape is proper.
RULING
Yes, the conviction is proper. The Supreme Court affirmed the trial court’s decision, finding the prosecution’s evidence sufficient to establish rape beyond reasonable doubt and rejecting the defense of consensual sex. The Court found the complainant’s testimony credible, straightforward, and consistent with human experience. Her immediate act of reporting the assault, submitting to a medical examination, and filing a complaint is contrary to the behavior of a consenting sweetheart and instead indicates a violated victim. The medical findings corroborated her claim of recent sexual intercourse and force.
The Court gave no credence to Mancilla’s sweetheart defense, deeming it a common and often fabricated excuse in rape cases. His narrative of an incredibly swift courtship, given they had just met, was implausible and unsupported by any evidence other than his self-serving testimony. The Court noted that his boastful claims about his romantic conquests only served to underscore his lack of credibility. The absence of external physical injuries on the complainant did not negate rape, as the threat with a dagger was sufficient to produce fear and subdue her resistance. The totality of the evidence conclusively proved that the sexual act was accomplished through force and intimidation, not mutual consent.