PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 191250, February 6, 2013.

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 (RTC) found Ibarra guilty of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals (CA) affirmed the RTC’s decision. Ibarra appealed to the Supreme Court, arguing that the testimony of AAA was not credible.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape based on the credibility of the victim’s testimony.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction. The Court held that the testimony of the victim, AAA, was clear, convincing, and consistent with human nature and the normal course of things. The Court emphasized the well-entrenched doctrine that the trial court’s assessment of the credibility of witnesses is entitled to great weight and respect, as it had the direct opportunity to observe their demeanor and deportment on the stand. No compelling reason was shown to deviate from this rule. The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and categorical identification by the victim. The Court also noted that the charge of rape, especially when committed by a father against his own daughter, is difficult to prove as it is usually only the victim who can testify to its occurrence. AAA’s detailed and unwavering testimony, which withstood rigorous cross-examination, was sufficient to establish Ibarra’s guilt beyond reasonable doubt. The penalties and awards of damages were affirmed with modification, increasing the amount of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.