PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOSELITO YBAÑEZ y GARCIA, Accused-Appellant. G.R. No. 234217. October 16, 2019.

FACTS:
Joselito Ybañez was charged with the crime of Rape under Article 266-A of the Revised Penal Code, as amended. The prosecution alleged that on December 25, 2012, Ybañez, by means of force, threat, and intimidation, had carnal knowledge of his 13-year-old niece, AAA. The Regional Trial Court (RTC) found Ybañez guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision. Ybañez appealed to the Supreme Court, raising the sole issue of whether his guilt was proven beyond reasonable doubt. He argued that the testimony of AAA was inconsistent and incredible.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Joselito Ybañez for the crime of Rape, based on the alleged insufficiency of evidence and incredibility of the victim’s testimony.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of Joselito Ybañez for Qualified Rape. The Court held that the prosecution successfully proved his guilt beyond reasonable doubt.

The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. The testimony of AAA was found to be straightforward, candid, and consistent on material points. The alleged inconsistencies referred to by the defense were minor and pertained to trivial details, which did not affect the core narrative of the crime. The Court reiterated that testimonies of child-victims are given full weight and credit, as youth and immaturity generally make them incapable of fabricating tales of sexual abuse.

Furthermore, the Court noted that the qualifying circumstance of minority (AAA being 13 years old) and relationship (Ybañez being the uncle of AAA) were both alleged in the Information and proven during trial. Under Article 266-B of the Revised Penal Code, when the victim is under 18 years of age and the offender is a relative within the third civil degree of consanguinity, the crime is Qualified Rape punishable by *reclusion perpetua* to death*. However, with the passage of Republic Act No. 9346, the penalty was reduced to *reclusion perpetua* without eligibility for parole.

The defense of denial and alibi proffered by Ybañez was deemed weak and could not prevail over the positive and credible identification made by the victim. Accordingly, the Supreme Court affirmed the decision of the Court of Appeals, with the modification that Ybañez is ordered to pay AAA civil indemnity, moral damages, and exemplary damages, all with legal interest.

*The decision was rendered prior to the enactment of Republic Act No. 11648, which raised the age of statutory rape to 16 years.