PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726 , February 6, 2013.

FACTS:
Accused-appellant 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, who was 13 years old at the time of the alleged incident. AAA testified that Bartolome, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed the denial and alibi of the accused, claiming he was elsewhere at the time. The Regional Trial Court (RTC) convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

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 testimony of the private complainant and the failure of the prosecution to prove guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals convicting accused-appellant Joselito Bartolome of rape.

The Court held that the testimony of the victim, AAA, was credible, categorical, and consistent on material points. The alleged inconsistencies referred to by the defense pertained to minor details which did not undermine the core narrative of the crime. The Court reiterated the doctrine that testimonies of child-victims of rape are given full weight and credit, as youth and immaturity generally make them incapable of fabricating tales of sexual abuse. Denial and alibi, being weak defenses, cannot prevail over the positive and credible identification by the victim. All elements of rape under Article 266-A were sufficiently proven: (1) the accused had carnal knowledge of the victim; and (2) such act was accomplished through force or intimidation. The award of damages by the lower courts was also sustained, with modifications in accordance with prevailing jurisprudence.