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

DOCTRINE: The crime of rape is committed by any person who shall have carnal knowledge of a woman under any of the following circumstances: (1) through force, threat, or intimidation; (2) when the offended party is deprived of reason or otherwise unconscious; or (3) when the offended party is under twelve (12) years of age or is demented. In statutory rape under paragraph 1(d), Article 266-A of the Revised Penal Code, as amended, the twin elements of carnal knowledge and the victim’s age below twelve (12) years are sufficient to sustain a conviction. Force, threat, or intimidation, or the victim’s lack of consent, need not be proven. The victim’s credible testimony, coupled with the medical findings and the certificate of live birth proving her age, constitutes proof beyond reasonable doubt.

FACTS

On June 26, 2009, AAA (a minor whose real name is withheld), then 11 years old, was at her aunt’s house in Quezon City. Her uncle, the accused-appellant Joselito Ibarra y Bellen, arrived and told her to go upstairs. Inside a room, Ibarra pushed AAA onto a bed, removed her shorts and underwear, and proceeded to have sexual intercourse with her against her will. AAA felt pain and cried. After the act, Ibarra threatened to kill her if she told anyone. AAA eventually reported the incident to her mother, BBB, who noticed her daughter’s unusual behavior. A medical examination revealed healed hymenal lacerations consistent with sexual intercourse. A Certificate of Live Birth confirmed AAA was born on October 10, 1997, making her 11 years old at the time of the rape. Ibarra was charged with rape. The Regional Trial Court (RTC) found him guilty beyond reasonable doubt of statutory rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant Joselito Ibarra y Bellen’s conviction for the crime of statutory rape.

RULING

YES. The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals convicting accused-appellant of statutory rape.

The Court upheld the conviction based on the following:
1. Elements of Statutory Rape: For rape under Article 266-A(1)(d) where the victim is below 12 years old, the prosecution must only prove: (a) that the accused had carnal knowledge of the victim; and (b) that the victim was below 12 years old at the time. Both elements were conclusively established.
2. Proof of Age: AAA’s Certificate of Live Birth, a public document, proved she was born on October 10, 1997, and was therefore 11 years old on June 26, 2009. This document enjoys the presumption of authenticity and was not rebutted by the defense.
3. Credibility of Testimony: AAA gave a clear, candid, and consistent account of the rape. The trial court’s assessment of her credibility is accorded great weight and respect, as it had the direct opportunity to observe her demeanor. Minor inconsistencies in her testimony regarding peripheral details do not undermine her core account of the sexual assault.
4. Medical Findings: The medico-legal report showing healed hymenal lacerations corroborated AAA’s testimony that she was sexually penetrated.
5. Defense of Denial: Ibarra’s defense of denial and alibi cannot prevail over the positive and credible identification by the victim. Denial is inherently weak and, if not substantiated by clear and convincing evidence, deserves no weight in law.
6. Proper Penalty and Damages: The penalty of *reclusion perpetua* without eligibility for parole is proper for statutory rape under Republic Act No. 9346 . The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages, each in the amount of P75,000.00, and interest on all damages at 6% per annum from finality of judgment until fully paid.