PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA Y PANCHO, Accused-Appellant. G.R. No. 191250, April 6, 2011.

FACTS:
Accused-appellant Joselito Ibarra was charged with the crime of rape committed against his 13-year-old daughter, AAA. The prosecution presented AAA’s testimony detailing how her father, on two separate occasions, had sexual intercourse with her through force and intimidation. The defense interposed denial and alibi, claiming AAA was coerced by her mother to fabricate the charges due to marital discord. The Regional Trial Court convicted Ibarra of two counts of rape and sentenced him to death. On automatic review, the Supreme Court initially affirmed the conviction but modified the penalty to reclusion perpetua, in line with the abolition of the death penalty under Republic Act No. 9346 .

ISSUE

Whether the Supreme Court correctly affirmed the conviction of the accused-appellant for two counts of rape based on the credibility of the victim’s testimony and the failure of the defense to rebut the presumption of guilt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court held that the testimony of the victim, AAA, was credible, categorical, and consistent. The defense of denial and alibi cannot prevail over the positive identification and straightforward narration of the victim. The Court emphasized that in rape cases, the credibility of the victim is paramount, and when her testimony passes the test of credibility, a conviction may be sustained. The alleged ill-motive of the mother was insufficient to overturn the conviction, as no daughter would fabricate a story of rape against her own father unless it were true. The penalty was properly modified to reclusion perpetua for each count, and the awards of civil indemnity, moral damages, and exemplary damages were affirmed in accordance with prevailing jurisprudence.