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 13 years old at the time of the incident. AAA testified that Ibarra, a neighbor and friend of her family, sexually assaulted her inside his 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’s 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 prosecution successfully established all the elements of rape through the credible, categorical, and consistent testimony of AAA. The Court emphasized the well-entrenched doctrine that the testimony of a rape victim, if credible, is sufficient to support a conviction. Minor inconsistencies in AAA’s testimony regarding peripheral details did not undermine her core narrative of the sexual assault and were, in fact, indicative of truthfulness. The Court found no ill motive for AAA to falsely accuse Ibarra. The defenses of denial and alibi, which are inherently weak and self-serving, could not prevail over AAA’s positive identification. The Court also affirmed the awards of damages, modifying them to conform to prevailing jurisprudence: P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with legal interest at 6% per annum from finality of judgment until fully paid.