PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 218592. January 11, 2017.

FACTS: Joselito Ibarra y Gonzales was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution’s case rested primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Ibarra, a neighbor, forcibly had sexual intercourse with her inside his house. The defense, on the other hand, interposed denial and alibi, claiming Ibarra was elsewhere during the alleged rape. The Regional Trial Court (RTC) convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision in toto. Ibarra appealed to the Supreme Court.

ISSUE

Whether the guilt of the accused-appellant, Joselito Ibarra y Gonzales, for the crime of rape has been proven beyond reasonable doubt.

RULING

No. The Supreme Court ACQUITTED accused-appellant Joselito Ibarra y Gonzales on the ground of reasonable doubt. The Court found that the prosecution failed to prove his guilt with the required moral certainty.

The Court meticulously reviewed the testimony of AAA and found material inconsistencies and irreconcilable contradictions regarding the *corpus delicti* of the crimespecifically, the details of the alleged sexual act and the use of force or intimidation. The testimony lacked the clear, consistent, and convincing quality necessary to sustain a conviction for rape, a grave offense that carries the severest penalty. The Court emphasized that in rape cases, the testimony of the complainant must be scrutinized with extreme caution, and her credibility must be established beyond reasonable doubt. Where the evidence for the prosecution is weak and betrays lack of concreteness, the constitutional presumption of innocence must prevail. The prosecution’s failure to discharge its burden of proof warranted an acquittal.