PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 191250, April 6, 2015

FACTS

Accused-appellant Joselito Ibarra 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 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) convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision in toto.

ISSUE

Whether the guilt of accused-appellant Joselito Ibarra for the crime of rape has been proven beyond reasonable doubt.

RULING

No. The Supreme Court ACQUITTED accused-appellant Joselito Ibarra on the ground of reasonable doubt.

The Court emphasized that in rape cases, the conviction of the accused must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The testimony of the complainant must be scrutinized with extreme caution and must be credible, natural, convincing, and consistent with human nature and the normal course of things.

In this case, the Court found the testimony of AAA fraught with serious inconsistencies and improbabilities that cast doubt on the truthfulness of her account. Key among these were: (1) her varying statements on how she was brought inside the accused’s house; (2) the implausibility of the rape occurring in a small, open space of the house without any immediate family member present in the adjoining rooms hearing any struggle or commotion; (3) her conduct immediately after the alleged incidentreturning to her friends to play, and only reporting the rape days later upon her mother’s discovery of her stained underwearwas contrary to the natural behavioral response of a young rape victim. The delay in reporting, coupled with the lack of a credible explanation for it, further eroded her credibility.

The Court held that these inconsistencies and improbabilities touched upon material points of the narrative and created reasonable doubt as to whether the crime of rape indeed occurred. When the evidence for the prosecution fails to meet the test of moral certainty and does not overcome the constitutional presumption of innocence, the accused must be acquitted. Accordingly, the Court reversed the decisions of the lower courts and ordered the immediate release of accused-appellant unless he is being lawfully held for another cause.