PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 191250, June 6, 2011.

FACTS:
Accused-appellant Joselito Ibarra y Gonzales was charged with the crime of rape committed against his 13-year-old daughter, AAA. The prosecution presented AAA’s testimony detailing how her father, on two separate occasions, sexually assaulted her inside their home. The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents. The Regional Trial Court convicted Ibarra of two counts of rape qualified by the minority of the victim and her relationship to the accused, sentencing him to death. The case was automatically elevated to the Supreme Court for review due to the death penalty imposed.

ISSUE

Whether the guilt of accused-appellant Joselito Ibarra for the crime of qualified rape has been proven beyond reasonable doubt.

RULING

YES, the accused-appellant is guilty of qualified rape. The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimony of the victim, AAA, to be credible, categorical, consistent, and convincing. The defense of denial and alibi cannot prevail over the positive and straightforward identification by the victim, who had no ill motive to falsely accuse her own father. The qualifying circumstances of minority (AAA being below 18 years old) and relationship (the offender being the parent of the victim) were duly proven by the victim’s birth certificate and her testimony. However, in light of Republic Act No. 9346 prohibiting the imposition of the death penalty, the Supreme Court modified the penalty to *reclusion perpetua* without eligibility for parole for each count of rape. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.