PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 191250, February 6, 2013.

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, sexually assaulted her inside their home. The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents. The Regional Trial Court convicted Ibarra of two counts of rape qualified by the minority of the victim and the relationship of father and daughter, sentencing him to death. On automatic review, the case was transferred to the Court of Appeals, which affirmed the conviction but modified the penalty to reclusion perpetua without eligibility for parole, in accordance with the abolition of the death penalty under Republic Act No. 9346.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Joselito Ibarra for two counts of qualified rape.

RULING

Yes, the Court of Appeals’ decision is affirmed. The Supreme Court upheld the conviction, finding that all elements of qualified rape under Article 266-A of the Revised Penal Code, as amended, were proven beyond reasonable doubt. The Court gave full credence to AAA’s candid, consistent, and straightforward testimony, which withstood rigorous cross-examination. The defense of denial and alibi, inherently weak and uncorroborated, could not prevail over the positive identification and credible testimony of the victim. The qualifying circumstances of minority (AAA being below 18) and relationship (father-daughter) were duly alleged in the informations and proven during trial. The penalty imposed by the Court of Appealsreclusion perpetua without eligibility for parole for each count of rapeis correct pursuant to prevailing law. The awards of damages were also modified in line with current jurisprudence.