PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 218592. January 11, 2017.

FACTS: Joselito Ibarra y Gonzales was charged with the crime of Rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353. The prosecution alleged that on December 25, 2004, in Pasig City, the accused, by means of force, threat, and intimidation, had carnal knowledge of AAA, a minor under 12 years of age. The Regional Trial Court (RTC) found Ibarra guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision. Ibarra appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, claiming the testimony of AAA was inconsistent and incredible.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape, despite alleged inconsistencies in the victim’s testimony.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction. The Court held that minor inconsistencies in the testimony of a rape victim, especially a child, do not impair her credibility but rather strengthen it by negating any suspicion of rehearsed testimony. The Court emphasized the well-entrenched doctrine that the testimony of a rape victim, particularly a minor, is accorded full weight and credit. The lone testimony of the victim, if credible, is sufficient to sustain a conviction. In this case, AAA’s categorical, straightforward, and consistent narration of how she was sexually assaulted by the appellant was found to be credible and convincing. The medical findings, which indicated hymenal lacerations, corroborated her claim of penetration. The defense of denial and alibi proffered by the appellant was weak and could not prevail over the positive identification and credible testimony of the victim. The Supreme Court thus affirmed the decision of the Court of Appeals, with modification increasing the amount of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.