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 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 incident. AAA testified that Ibarra, her stepfather, sexually assaulted her inside their home. The defense interposed denial and alibi, claiming Ibarra was elsewhere during the alleged incident. The Regional Trial Court convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Ibarra appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in AAA’s testimony and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of rape, despite the alleged inconsistencies in the testimony of the private complainant and the absence of medical evidence.

RULING

NO. The Court of Appeals did not err. The conviction is affirmed.

The Supreme Court held that the alleged inconsistencies in AAA’s testimony pertained to minor and trivial details that did not affect the core of her narrativethat she was sexually violated by her stepfather. Inconsistencies on minor matters may even enhance a witness’s credibility, as they indicate that the testimony was not rehearsed. The Court emphasized that the testimony of a rape victim, especially a minor, is accorded great weight and credibility. A young girl would not ordinarily concoct a story of defloration, undergo the ordeal of a public trial, and tarnish her reputation unless she was motivated by a sincere desire to seek justice for a grievous wrong done to her.

Furthermore, the Court ruled that the absence of medical evidence is not fatal to the prosecution’s case. In rape, the essential element is carnal knowledge, which can be proven by the credible testimony of the victim alone. Medical findings are merely corroborative, not indispensable. The clear, positive, and categorical testimony of AAA, which the trial court found credible, is sufficient to sustain a conviction.

The defense of denial and alibi, which Ibarra presented, is inherently weak and cannot prevail over the positive identification and credible testimony of the victim. Denial is a self-serving negative evidence that deserves no weight in law when placed against the affirmative testimony of a credible witness.

Accordingly, the Supreme Court affirmed the decision of the Court of Appeals finding accused-appellant Joselito Ibarra y Gonzales guilty beyond reasonable doubt of the crime of rape and sentencing him to suffer the penalty of *reclusion perpetua*. He was also ordered to pay civil indemnity, moral damages, and exemplary damages to the victim.