In People v. Velasco, the Supreme Court affirmed the conviction of Blesie Velasco for the rape of his 12-year-old stepdaughter, Raquel Yasas, rejecting his defense of a consensual ‘sweetheart’ relationship. The court emphasized the credibility of the victim’s testimony, the moral ascendancy of the stepfather, and the lack of improper motive on the part of the victim in bringing the charges. This decision reinforces the protection of children from abuse by those in positions of trust and underscores the court’s willingness to uphold convictions based on the victim’s account, even in the absence of physical evidence.

When Family Turns Predator: Can a Stepfather’s ‘Sweetheart’ Claim Excuse Rape?

Blesie Velasco stood accused of the unthinkable: the rape of his 12-year-old stepdaughter, Raquel Yasas. The incidents allegedly occurred in 1996 and 1997, in Iloilo. Velasco, however, offered a shocking defense. He claimed that he and Raquel were lovers, engaged in consensual sexual relations. This so-called “sweetheart theory” was presented to explain away the charges, arguing that the encounters were not forced but based on mutual affection. The Regional Trial Court of Iloilo City, however, found Velasco guilty, sentencing him to death for each of the three counts of rape. The case then reached the Supreme Court for automatic review, prompting the high court to evaluate the credibility of the victim’s testimony and the validity of the accused’s defense.

The defense raised several points to challenge Raquel’s credibility. They argued that her testimony was inconsistent, particularly regarding the weapon used by the accused during the assaults. The defense highlighted her claim that Velasco threatened to kill her mother, who was already absent from their home, as illogical. They also pointed to the absence of physical injuries on Raquel’s body, despite her claims of resistance, and the delay in reporting the incidents as evidence against the veracity of her account. The defense further suggested that Raquel had opportunities to escape and that inconsistencies in her testimony regarding her menstrual cycle cast doubt on her claims. These arguments formed the crux of Velasco’s appeal, attempting to undermine the victim’s narrative and introduce reasonable doubt.

The Supreme Court, however, found these arguments unpersuasive. The court emphasized that inconsistencies in a rape victim’s testimony, particularly a child, are not uncommon and do not necessarily discredit their account, citing People v. Historillo, G.R. No. 130408, 16 June 2000. The court noted the moral ascendancy of a stepfather over a young stepdaughter, which could explain her initial silence and failure to escape, referencing People v. Dalafu, G.R. No. 127156, 31 July 2000. Additionally, the court acknowledged the victim’s age and the trauma she experienced as factors that could affect her memory and recall of specific details. This consideration of the victim’s circumstances played a crucial role in the court’s assessment of her credibility.

Building on this principle, the Supreme Court affirmed the trial court’s assessment that Raquel’s testimony was credible. The court emphasized that the testimony of a rape victim, especially a child, is given significant weight, citing People v. Diasanta, G.R. No. 128108, 6 July 2000. The court also noted that matters of credibility are best left to the trial court, which has the opportunity to observe the witness’s demeanor. The Court reiterated that it will respect factual findings of trial courts when such findings are supported by substantial evidence. In cases involving crimes against chastity, the testimony of the victim is given even greater weight. The Court emphasized that the trial court is in the best position to assess the credibility of witnesses.

The accused attempted to paint the victim as harboring ill motives, suggesting that she fabricated the rape charges to retaliate for his past abuse of her mother. However, the Supreme Court found this argument to be contradictory and unconvincing. The Court also cited People v. Gementiza, G.R. No. 123151, 29 January 1998, 285 SCRA 478, where it stated that where there is no showing that the complainant was impelled by any improper motive in making the accusation against the accused, her complaint is entitled to full faith and credit.

Turning to the penalty, the Supreme Court acknowledged the strict requirements for imposing the death penalty in qualified rape cases. It is essential that the minority of the victim and the relationship of the offender be alleged and proven with certainty, as stated in People v. Alcala, G.R. Nos. 127023-25, 19 May 1999, 307 SCRA 330. The Court highlighted that previous cases had refused to impose the death penalty when the prosecution failed to present independent evidence, such as a birth certificate, to substantiate the victim’s minority.

However, the Court distinguished the present case, noting that the victim’s testimony regarding her age was admissible, citing People v. Silvano, G.R. No. 127356, 29 June 1999, 309 SCRA 362. The High Court held that the testimony of a person as to her age is admissible even though it is hearsay, for she can have no personal knowledge of the date of her birth, as knowledge as to one’s age is acquired from whatever is told by the parents or relative – and such testimony constitutes an assertion of family tradition. Moreover, the accused himself admitted that the victim was a minor. Considering all these factors, the Supreme Court concluded that the victim’s minority was established with certainty, thereby justifying the imposition of the death penalty.

The Court also addressed the civil liability of the accused. It affirmed the award of moral damages, recognizing that such damages may be awarded in rape cases without requiring specific pleading or proof. The Court also affirmed the award of exemplary damages. However, in line with prevailing jurisprudence, the Court increased the civil indemnity from P50,000.00 to P75,000.00 for each count of rape, given that the offenses were qualified by circumstances that warranted the death penalty under Republic Act No. 7659. This adjustment reflects the gravity of the crimes committed and the need to provide adequate compensation to the victim.

FAQs

What was the key issue in this case?	The central issue was whether the accused, Blesie Velasco, was guilty of raping his stepdaughter, despite his claim that their relationship was consensual. The Court had to determine the credibility of the victim’s testimony and whether the prosecution proved its case beyond a reasonable doubt.
Why did the accused claim the relationship was consensual?	Blesie Velasco presented a “sweetheart theory,” arguing that he and his stepdaughter were lovers who engaged in consensual sexual relations. He used this defense to attempt to negate the rape charges, asserting that the encounters were not forced but based on mutual affection.
Did the medical examination show evidence of rape?	While the medical examination confirmed that the victim was not a virgin, it did not reveal external signs of violence or traces of spermatozoa. However, the Supreme Court noted that the examination took place seventeen days after the last alleged incident, and any injuries might have healed by then.
Why did the Court give weight to the victim’s testimony?	The Court emphasized that the testimony of a rape victim, especially a child, is given significant weight. It also recognized the moral ascendancy of a stepfather over a young stepdaughter, which could explain her initial silence and failure to escape.
What was the significance of the victim’s age in this case?	The victim’s age was a crucial factor, as the minority of the victim is a qualifying circumstance that can lead to a more severe penalty, including the death penalty. The Court had to determine whether the victim’s minority was proven with certainty.
How did the Court determine the victim’s age?	The Court relied on the victim’s testimony regarding her date of birth, which it considered admissible as an assertion of family tradition. Additionally, the accused himself admitted that the victim was a minor, and the trial court made a categorical finding that she was a minor.
What were the civil liabilities imposed on the accused?	The accused was ordered to pay moral damages and exemplary damages. The civil indemnity was increased to P75,000.00 for each count of rape, reflecting the gravity of the offenses.
What is the practical takeaway from this ruling?	The ruling affirms that, in cases of rape, especially when the victim is a minor and the perpetrator is in a position of trust, the victim’s testimony is given considerable weight. It also highlights that a defense of consensual relationship is unlikely to succeed when there is a significant power imbalance and the victim is a child.

In conclusion, People v. Velasco serves as a stark reminder of the importance of protecting children from abuse and holding perpetrators accountable. The decision underscores the court’s commitment to upholding the rights of victims and ensuring that those who violate positions of trust are brought to justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Blesie Velasco, G.R. Nos. 135231-33, February 28, 2001