PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726 , February 6, 2012.

FACTS:
Joselito Bartolome was charged with the crime of rape under Article 266-A of the Revised Penal Code, as amended. The prosecution’s case relied primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Bartolome, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed 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. On appeal to the Supreme Court, Bartolome argued, among others, that the prosecution failed to prove his guilt beyond reasonable doubt, highlighting alleged inconsistencies in AAA’s testimony.

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 rape cases, the accused may be convicted solely on the basis of the victim’s testimony, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things. The Court found AAA’s testimony to be clear, straightforward, and consistent on material points. The alleged inconsistencies referred to by the defense pertained to minor and trivial details which did not affect the core of her narrative regarding the commission of the rape. Such minor inconsistencies may even strengthen credibility, as they negate any suspicion of rehearsed testimony. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor and manner of testifying. The defense of denial and alibi, being inherently weak, cannot prevail over the positive and categorical identification by the victim. All elements of rape under Article 266-A were sufficiently proven. The Supreme Court thus affirmed the judgment of the Court of Appeals, with modification increasing the amount of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.