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 alleged incident. AAA testified that Ibarra, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Ibarra was elsewhere during the alleged rape. 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. Ibarra appealed to the Supreme Court.

ISSUE

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

RULING

NO. The accused-appellant is ACQUITTED on the ground of reasonable doubt.

The Supreme Court reversed the convictions. While it reiterated the doctrine that the testimony of a rape victim, if credible, is sufficient to convict, the Court found that the prosecution failed to establish the guilt of the accused beyond reasonable doubt. The Court meticulously scrutinized the testimony of AAA and identified material inconsistencies and irreconcilable contradictions regarding the *corpus delicti* of the crimespecifically, the details of the alleged sexual act and the use of force or intimidation. These inconsistencies pertained to the very fact of the commission of the rape itself and cast serious doubt on the veracity of the complainant’s narrative. The Court emphasized that in criminal cases, the evidence for the prosecution must stand on its own strength and cannot draw strength from the weakness of the defense. Where the prosecution’s evidence is fraught with doubts, the constitutional presumption of innocence must prevail. Consequently, the Court acquitted Ibarra and ordered his immediate release from detention, unless he is being held for another lawful cause.