For the sweetheart theory defense to prosper, it must be proven with compelling evidence that: (1) the accused and the victim were lovers; and (2) she consented to the alleged relations. As proof of the relationship, evidence such as letters, documents, photographs, or concrete proof of a romantic nature must be proffered. The second requirement must also be established, for it is as important as the first. Love is not a license for lust. A love affair does not justify rape, for the beloved cannot be sexually violated against her will. (Toralde v. People, G.R. No. 264724, 3 February 2025)
In Monroy v. People (G.R. No. 235799, 29 July 2019), the Supreme Court acquitted the accused as the private complainant therein admitted in open court having authored a letter to the accused, and in that letter, she declared her love for the accused, and admitted that the charge of rape was concocted to retaliate against the accused who wanted to go home to the province.
However, in Torralde v. People (G.R. No. 264724, 3 February 2025), the accused’s sweetheart defense was not given credence since the alleged proof of the consent – the undated letters purportedly from the victim – were not authenticated, nor did she admit to the same. There was no confirmation also in the letter of the alleged consented sexual relations. The video offered supposedly showing the consent was unauthenticated, and the origin thereof was also admittedly unknown. While the victim admitted to being in a romantic relationship with the accused, this does not negate or rule out the commission of rape.