G.R. No. 42142 - Bachrach Motor Co., Inc. vs. Albert

The appellant, Ruben Corpuz y Simon, was charged with six counts of rape committed against his alleged stepdaughter, referred to as AAA, in six separate Informations.
Each Information alleged that between April and September 2002 at Barangay Caglayan, Conner, Apayao, the accused, with lewd designs, used force or intimidation (or, in the absence of overt physical force, moral ascendancy) to have carnal knowledge with AAA, a minor under eighteen years of age.
The rape was further aggravated by the alleged familial relationship—alleging that the appellant is the stepfather of the victim—which qualifies as an aggravating circumstance.

During arraignment, the appellant pleaded not guilty.
Although he admitted having had sexual intercourse with AAA on several occasions, he claimed that there was no force or intimidation involved, invoking what became known as the "sweetheart" defense.
The prosecution’s evidence principally relied on AAA’s detailed testimony and the supportive evidence from a medical examination, social case study report, and corroborative circumstance reports.
Testimony and evidence noted that:

The incidents took place repeatedly from April to September 2002, often when AAA’s mother, BBB, was away.
Appellant allegedly entrapped AAA in a room armed with a gun and a knife, threatening to kill both AAA and her mother.
AAA stated she could not recall the exact number of occurrences and only disclosed the abuse after suspecting a possible pregnancy when her menstrual cycle stopped.
Subsequent physical and psychological examinations corroborated signs of trauma, such as lacerations on the hymen and indications of emotional distress.

The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt of six counts of qualified rape, imposing the death penalty for each offense, along with awards for moral, exemplary, and civil damages.
On automatic review, the Court of Appeals affirmed the conviction but modified:

The crime was re-characterized from qualified rape to simple rape.
The appellant was sentenced to reclusion perpetua for each offense.
The damages were revised, with the civil indemnity reduced from P75,000 to P50,000 per count, while maintaining the moral and exemplary damages.

The primary evidence against the appellant was AAA’s consistent and straightforward testimony, which was deemed credible due to her clear and unflinching responses during cross-examination.
The appellant's defense ("sweetheart" theory) was self-serving and unsupported by any documentary or corroborative evidence (e.g., love letters, photographs, or other mementos).
Confusion existed regarding the qualification of the crime; while the allegations pointed to a stepfather-stepdaughter relationship, questions arose whether the relationship was accurately and legally established since the information only alleged that the appellant was the live-in partner of AAA’s mother, BBB.

Whether the trial court properly accorded credibility to AAA’s testimony given her consistent account and demeanor during cross-examination.
Whether the evidence was sufficient to disprove the appellant’s "sweetheart" defense that downplayed the element of force or intimidation.

Whether the rape should be classified as qualified rape or as simple rape based on:

The alleged age of the victim (minorhood was clearly proved).
The precise nature of the relationship between the appellant and the victim, and whether the qualifying circumstance of a stepfather-stepdaughter relationship was adequately alleged and proved.

Whether the failure to establish that the appellant was married to AAA’s mother (as opposed to being merely her live-in partner) affects the applicability of the aggravating circumstance.

The standard of proof required for the affirmative "sweetheart" defense and whether the appellant met his burden by presenting convincing corroborative evidence.
Whether the inherent nature of moral ascendancy in close familial relations can substitute for the demonstration of physical force or intimidation.