PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726, February 6, 2013.

FACTS:
Joselito Bartolome was charged with the crime of rape under Article 266-A of the Revised Penal Code. The prosecution’s case rested primarily on the testimony of the private complainant, AAA, who was 12 years old at the time of the alleged incident. AAA testified that Bartolome, her neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed the defense of denial and alibi, claiming Bartolome was elsewhere at the time. The Regional Trial Court convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly questioning AAA’s credibility and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape based on the testimony of the private complainant.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.

In reviewing rape cases, the Court is guided by the long-standing principles that: (1) an accusation for rape can be made with facility and is difficult to prove but even more difficult for the person accused, though innocent, to disprove; (2) in view of the intrinsic nature of the crime, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits and cannot draw strength from the weakness of the defense.

The Court found that the prosecution’s evidence, particularly the categorical, straightforward, and consistent testimony of AAA, met the test of credibility. The trial court’s assessment of the witness’s credibility is entitled to great weight and respect, as it had the direct opportunity to observe her demeanor and sincerity. AAA’s testimony contained the essential details of force, intimidation, and carnal knowledge. The Court held that the testimony of a lone witness, if credible and positive, is sufficient to sustain a conviction for rape. The defense of denial and alibi, which are inherently weak defenses, cannot prevail over the positive identification by the victim. The absence of medical evidence or physical injury does not negate the commission of rape, as the law does not impose a requirement of corroboration. Consequently, the Supreme Court affirmed the decision of the Court of Appeals in toto.