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 forcibly had sexual intercourse with 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 has been 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 recognizes the gravity of the crime of rape and the profound trauma suffered by victims, a conviction must rest on proof beyond reasonable doubt. In this case, the prosecution’s evidence failed to meet this stringent standard. The Court found material inconsistencies and improbabilities in AAA’s testimony regarding the manner and circumstances of the alleged rape, which cast serious doubt on its credibility. The testimony did not cohere with human experience and ordinary course of things. When the testimony of the complainant is fraught with inconsistencies and improbabilities, it cannot sustain a conviction. The constitutional presumption of innocence prevails, and any doubt is resolved in favor of the accused. Joselito Bartolome was ordered immediately released from detention unless held for another lawful cause.