PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 218592. January 11, 2017.

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 incident. AAA testified that Ibarra, her stepfather, sexually assaulted her inside their house. The defense interposed denial and alibi, claiming Ibarra was elsewhere at the time. The Regional Trial Court (RTC) found Ibarra guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Ibarra appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape, despite alleged inconsistencies in the testimony of the private complainant and the failure of the prosecution to prove guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Joselito Ibarra y Gonzales for the crime of rape. The Court held that the testimony of the victim, AAA, was credible, categorical, and consistent on material points. The Court emphasized that in rape cases, the credibility of the victim is of utmost importance. Minor inconsistencies in her testimony regarding peripheral details did not undermine her core narrative of the sexual assault, and may even indicate truthfulness. The defense of denial and alibi, being inherently weak, cannot prevail over the positive and credible identification by the victim. All elements of rape under Article 266-A were sufficiently proven: (1) Ibarra had carnal knowledge of AAA, and (2) such act was accomplished through force or intimidation, considering his moral ascendancy as a stepfather and the victim’s tender age. The penalty of reclusion perpetua was affirmed, with modifications to the awarded damages in accordance with prevailing jurisprudence.