PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 191050, June 6, 2011

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 affirmed the RTC decision in toto.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of 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 appeal primarily hinges on the credibility of the victim, AAA. The Court reiterated the well-established 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, candor, and manner of testifying. The Court found no reason to deviate from the RTC and CA’s unanimous findings. AAA’s testimony was clear, candid, straightforward, and consistent on material points, bearing the hallmarks of truth. Her detailed account of the harrowing incidents, including the specific acts, the use of force and threat, and her subsequent actions, was credible and sufficient to establish the elements of rape.

The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and categorical testimony of the victim. The alleged motive of the mother to fabricate the charges was insufficient to overturn the conviction, especially in light of the gravity of the crime and the natural reluctance of a young daughter to accuse her own father falsely. All elements of rape under Article 266-A of the Revised Penal Code were proven beyond reasonable doubt: (1) sexual congress; (2) accomplished through force, threat, or intimidation; (3) with the victim under 12 years of age or demented at the time. The qualifying circumstance of relationship where the offender is the parent of the victim was also duly alleged and proven, warranting the penalty of reclusion perpetua without eligibility for parole. The awards of damages were modified in accordance with prevailing jurisprudence.