PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 218592, January 11, 2018

FACTS

Accused-appellant Joselito Ibarra y Gonzales 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 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 time. The Regional Trial Court (RTC) found Ibarra guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Ibarra appealed to the Supreme Court.

ISSUE

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

RULING

NO. The Court ACQUITS accused-appellant Joselito Ibarra y Gonzales on the ground of reasonable doubt. The prosecution failed to prove his guilt with the required moral certainty.

The Supreme Court meticulously reviewed the records and found the testimony of the private complainant, AAA, to be replete with inconsistencies and irreconcilable contradictions on material points. These pertained to the sequence of events, the specific location within the house where the rape allegedly occurred, the presence of other people, and the actions she took immediately after the incident. The Court emphasized that while testimonies of rape victims are generally accorded credence, this principle is not an absolute rule. When the testimony is fraught with inconsistencies that cast serious doubt on its veracity, it cannot be the sole basis for a conviction.

The Court held that the inconsistencies were not minor but affected the very narrative of the crime, thereby creating reasonable doubt as to whether the crime indeed transpired as alleged. In criminal cases, the burden of proof lies with the prosecution, and the evidence must establish the accused’s guilt beyond a shadow of doubt. Any doubt is resolved in favor of the accused. Here, the doubt created by the unreliable testimony of the sole eyewitness warranted an acquittal.

The decision of the Court of Appeals was REVERSED and SET ASIDE. Accused-appellant Joselito Ibarra y Gonzales was ordered IMMEDIATELY RELEASED from detention unless he is confined for any other lawful cause.