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 incident. AAA testified that Ibarra, her stepfather, sexually assaulted her inside their home. The defense interposed denial and alibi, claiming Ibarra was elsewhere during the alleged incident. The Regional Trial Court convicted Ibarra of Qualified Rape and sentenced him to reclusion perpetua without eligibility for parole. The Court of Appeals affirmed the conviction. Ibarra appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the guilt of accused-appellant Joselito Ibarra for the crime of Qualified Rape was proven beyond reasonable doubt.

RULING

YES, the Supreme Court AFFIRMED the conviction but MODIFIED the nomenclature of the crime and the penalty. The Court held that all elements of Rape under Article 266-A were present: (1) AAA was under 12 years old; (2) Ibarra had carnal knowledge of her; and (3) the act was accomplished through force or intimidation. AAA’s categorical, consistent, and straightforward testimony, which survived rigorous cross-examination, was found credible and sufficient to sustain a conviction. The defense of denial and alibi, being inherently weak and unsupported by clear and convincing evidence, could not prevail over AAA’s positive identification.

However, the Court CORRECTED the lower courts’ designation of the crime. Since the qualifying circumstance of relationship (as stepfather) was not alleged in the Information, the crime could not be “Qualified Rape” under Article 266-B. Instead, the age of the victim (under 12) made the crime Statutory Rape under Article 266-A(1)(d), which is punishable by *reclusion perpetua*. The Court also clarified that the special qualifying circumstance of minority and relationship under Article 266-B, which would warrant the death penalty, requires both conditions to be specifically alleged and proven. Since only minority was effectively alleged, the proper penalty is *reclusion perpetua* without eligibility for parole, pursuant to Republic Act No. 9346 . The award of damages was also modified in accordance with prevailing jurisprudence.