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

FACTS:
Joselito Bartolome was charged with the crime of rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353. The prosecution’s case relied primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Bartolome, her neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Bartolome was elsewhere during the alleged rape. The Regional Trial Court convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape, despite alleged inconsistencies in the testimony of the private complainant and the failure of the prosecution to prove guilt beyond reasonable doubt.

RULING

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

The Court held that in rape cases, the credibility of the victim’s testimony is paramount. The alleged inconsistencies in AAA’s testimony pertained to minor details and did not affect the core elements of the crime. The Court emphasized that testimonies of child-victims are given full weight and credit, as youth and immaturity generally make them incapable of fabricating a charge of such gravity. The straightforward, candid, and unwavering testimony of AAA on the essential fact of sexual violation was found credible and sufficient to sustain a conviction.

The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and credible identification by the victim. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to be at the scene of the crimea burden Bartolome failed to discharge.

All elements of rape under Article 266-A were duly proven: (1) AAA was under 12 years of age at the time (as evidenced by her birth certificate), and (2) Bartolome had carnal knowledge of her. The age of the victim, being below 12, makes the rape qualified under Article 266-B, warranting the penalty of *reclusion perpetua* without eligibility for parole. The award of damages was also modified in accordance with prevailing jurisprudence.