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

FACTS

Accused-appellant Joselito Ibarra 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, had sexual intercourse with her through force and intimidation. The defense interposed denial and alibi, claiming AAA was coerced by her mother to fabricate the charges due to marital discord. The Regional Trial Court (RTC) convicted Ibarra of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals (CA) affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape based on the credibility of the victim’s testimony.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.

The appeal primarily challenges the credibility of the victim, AAA. The Court reiterated the well-established doctrine that the trial court’s assessment of the credibility of witnesses is entitled to great weight and respect, as it had the direct opportunity to observe their demeanor and manner of testifying. No compelling reason was shown to deviate from this rule.

The Court found AAA’s testimony to be clear, candid, and consistent on material points, bearing the hallmarks of truth. Her detailed account of how her father abused his moral ascendancy and parental authority to force himself upon her was credible and convincing. The defense of denial and alibi, inherently weak and self-serving, could not prevail over the positive and categorical testimony of the victim. The alleged motive of the mother to fabricate the charges was insufficient to overturn the conviction, as the testimony of the victim alone, if credible, is sufficient to sustain a conviction for rape.

The crime committed is qualified rape under Article 266-A, paragraph 1(d) of the Revised Penal Code, as amended, as the victim is under eighteen (18) years of age and the offender is the parent of the victim. The penalty of *reclusion perpetua* for each count was correctly imposed. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages, subject to interest at the legal rate.