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 under Article 266-A of the Revised Penal Code. 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, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Bartolome was elsewhere at the time. 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, particularly challenging AAA’s credibility and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for rape, despite alleged inconsistencies in the victim’s testimony and the absence of medical corroboration.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that the testimony of the victim, AAA, was credible, consistent, and sufficient to establish the elements of rape. The Court reiterated the well-established doctrine that in rape cases, the credibility of the complainant is paramount. AAA’s straightforward and candid narration of the traumatic event, including the details of the force employed and the sexual act itself, bore the hallmarks of truth. The alleged inconsistencies in her testimony were minor and pertained to trivial details, which did not undermine the core of her account but instead indicated an unrehearsed testimony. The Court further ruled that medical evidence is not indispensable for a rape conviction; the victim’s credible testimony alone, if credible, is sufficient to sustain a finding of guilt beyond reasonable doubt. The defense of denial and alibi, being inherently weak and unsupported by clear and convincing evidence, could not prevail over the positive identification and credible testimony of the victim. Accordingly, the Court affirmed the penalty of reclusion perpetua and the awards of damages.