PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726 , February 6, 2012.

FACTS:
Accused-appellant Joselito Bartolome was charged with the crime of rape committed against his 13-year-old daughter, AAA. The prosecution presented AAA’s testimony detailing how her father, on two separate occasions, sexually assaulted her inside their home. The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents. The Regional Trial Court convicted Bartolome of two counts of rape qualified by the minority of the victim and the relationship, sentencing him to death. On automatic review, the case was transferred to the Court of Appeals pursuant to *People v. Mateo*. The Court of Appeals affirmed the conviction but modified the penalty to *reclusion perpetua* without eligibility for parole, in accordance with the amendment introduced by Republic Act No. 9346 prohibiting the death penalty.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for two counts of qualified rape based on the testimony of the victim.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.

The Court held that the testimony of the victim, AAA, was clear, candid, and consistent on material points, thereby satisfying the stringent standard required for conviction in rape cases. The Court emphasized that when the victim’s testimony is straightforward and unwavering, it is sufficient to establish the crime. The defense of denial and alibi, inherently weak and unsubstantiated by clear and convincing evidence, cannot prevail over the positive identification and credible testimony of the victim. The Court found that all elements of qualified rape under Article 266-A of the Revised Penal Code, as amended, were proven beyond reasonable doubt: (1) sexual congress; (2) accomplished through force or intimidation; (3) with the victim under 18 years of age at the time; and (4) the offender being the parent of the victim. The qualifying circumstances of minority and relationship were duly alleged in the informations and proven during trial. Accordingly, the penalty of *reclusion perpetua* without eligibility for parole was correctly imposed. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages.