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. The prosecution’s case relied primarily on the testimony of the private complainant, AAA, a minor. AAA testified that on the night of the incident, the accused, who was her neighbor and the common-law partner of her aunt, entered her room while she was sleeping, covered her mouth, threatened her with a knife, and sexually assaulted her. The defense interposed denial and alibi, claiming the accused 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. The case was elevated to the Supreme Court via automatic review.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

NO. The accused is ACQUITTED on the ground of reasonable doubt. The Supreme Court reversed the convictions. While the Court acknowledged that the testimony of a rape victim, especially a minor, is normally accorded great weight, it found that the prosecution failed to establish the guilt of the accused with the required moral certainty. The Court identified several material inconsistencies and improbabilities in AAA’s testimony regarding the manner and sequence of the alleged assault, which cast serious doubt on its credibility. Furthermore, the Court noted the lack of physical evidence and the questionable behavior of AAA and her family immediately after the alleged incident, which did not align with the natural reactions of victims of such a violent crime. The defense of alibi, while generally weak, assumed significance in light of the prosecution’s failure to discharge its burden of proof. The constitutional presumption of innocence prevailed. The accused was ordered immediately released from custody unless detained for another lawful cause.