PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y BELLEN, Accused-Appellant. G.R. No. 217630. January 15, 2020.

DOCTRINE: The crime of rape is consummated by the slightest penetration of the female organ. Emission is not required. Proof of hymenal laceration is not indispensable for a conviction, as medical findings are merely corroborative. The credibility of the victim’s clear, positive, and categorical testimony, especially when she is a minor, is paramount.

FACTS

On June 26, 2005, in Pasig City, AAA, then a 13-year-old minor, was alone in her house. Accused-appellant Joselito Ibarra, her neighbor and the common-law partner of her aunt, arrived and asked for water. After drinking, he suddenly embraced AAA from behind, kissed her, and laid her on the floor. He removed her shorts and panty, placed himself on top of her, and inserted his penis into her vagina. AAA felt pain and cried. Ibarra threatened to kill her if she reported the incident. AAA immediately reported the rape to her aunt and later underwent a medical examination. The Medico-Legal Report noted an old, healed hymenal laceration but no fresh injuries. Ibarra was charged with rape under Article 266-A of the Revised Penal Code. The Regional Trial Court convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Ibarra appealed to the Supreme Court, arguing that the absence of fresh lacerations and spermatozoa negated the commission of rape.

ISSUE

Whether the Court of Appeals erred in affirming Ibarra’s conviction for rape despite the absence of medical findings showing fresh hymenal lacerations or the presence of spermatozoa.

RULING

No, the Court of Appeals did not err. The appeal is dismissed, and the conviction is affirmed.

The Supreme Court held that the crime of rape is consummated by even the slightest penetration of the female organ. Emission is not an element. The medical findings, which indicated an old, healed hymenal laceration but no fresh injuries, do not disprove rape. The Court emphasized that medical examination results are not essential for conviction but are merely corroborative. The testimony of the victim, AAA, who was credible, consistent, and categorical in narrating how Ibarra sexually assaulted her, is sufficient to establish guilt beyond reasonable doubt. As a minor, her testimony is accorded full weight and credit. The defense of denial by Ibarra cannot prevail over her positive identification. The Court also affirmed the award of damages: P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with legal interest.