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, forced her to have sexual intercourse inside their house while her mother was at work. The medical examination revealed a healed hymenal laceration consistent with sexual intercourse. Ibarra denied the accusations, claiming they were fabricated due to a family conflict. The Regional Trial Court convicted Ibarra of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals affirmed the conviction.

ISSUE

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

RULING

Yes, the Supreme Court affirmed the conviction. The Court held that AAA’s testimony was credible, categorical, and consistent. In rape cases, the credibility of the victim is paramount. The Court found no ill motive for AAA to falsely accuse her own father of such a grave crime. Her testimony was corroborated by medical findings. The defense of denial, unsupported by clear and convincing evidence, cannot prevail over the positive and credible testimony of the victim. The elements of rape under Article 266-A of the Revised Penal Code, as amended, were duly established: (1) sexual congress took place; (2) it was accomplished through force or intimidation; and (3) the victim was under 12 years of age or was demented at the time of the rape. The qualifying circumstance of relationship (father-daughter) under Article 266-B was also proven, warranting the penalty of reclusion perpetua. The awards of damages were modified in accordance with prevailing jurisprudence.