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 12 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 of Rape and sentenced him to *reclusion perpetua*. The Court of Appeals (CA) affirmed the RTC’s decision in toto. Ibarra appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime 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 appeal is bereft of merit. The Supreme Court upheld the factual findings and assessment of credibility made by the trial court, as affirmed by the CA. The Court reiterated the well-entrenched doctrine that the trial court’s evaluation of the witnesses’ credibility is accorded great weight and respect, as it had the direct opportunity to observe their demeanor, conduct, and manner of testifying. No compelling reason was shown to deviate from this rule.

The Court found the testimony of AAA to be credible, straightforward, and consistent on material points. Her testimony alone, if credible, is sufficient to sustain a conviction for rape. The Court emphasized that when the victim’s testimony is credible, the accused may be convicted solely on that basis. The defense of denial and alibi, which are inherently weak defenses, cannot prevail over the positive and categorical identification made by the victim. Furthermore, for alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crimea burden Ibarra failed to discharge.

The Court also noted that the crime committed is Statutory Rape under Article 266-A(1)(d) of the Revised Penal Code, as amended, since AAA was under 12 years old at the time of the commission of the crime. In statutory rape, force, intimidation, or lack of consent is immaterial; the law presumes that a child below 12 years of age does not possess the discernment to give meaningful consent to a sexual act.

Accordingly, the Supreme Court AFFIRMED the Decision of the Court of Appeals which upheld the judgment of the RTC finding accused-appellant Joselito Ibarra y Gonzales GUILTY beyond reasonable doubt of the crime of Statutory Rape and sentencing him to suffer the penalty of *reclusion perpetua*, with all its accessory penalties, and ordering him to pay civil indemnity, moral damages, and exemplary damages to the victim.