FACTS:
Joselito Bartolome 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 Bartolome, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Bartolome was elsewhere at the time. The Regional Trial Court convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly questioning AAA’s credibility and the lack of medical evidence.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape based on the testimony of the private complainant.
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.
In rape cases, the credibility of the victim is paramount. The Court reiterated the well-established doctrine that the testimony of a rape victim, if credible, is sufficient to support a conviction. AAA’s testimony was clear, candid, and consistent on material points, and she remained steadfast during cross-examination. The Court found no ill motive for AAA, a young girl, to falsely accuse the appellant of such a grave crime. The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and credible identification by the victim. The absence of medical evidence or physical injury is not indispensable for a rape conviction, as the crime can be established by the victim’s credible testimony alone, especially when the force employed is more psychological than physical. All elements of rape under Article 266-A were sufficiently proven. The Supreme Court thus affirmed the decision of the Court of Appeals in toto.
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