PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BAGUIO y SANTOS, Accused-Appellant. G.R. No. 250875, June 15, 2022.

FACTS:
Accused-appellant Joselito Baguio y Santos was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution alleged that on a specific date and time, Baguio had carnal knowledge of the victim, AAA, a minor, through force, threat, and intimidation. The defense interposed the defense of denial and alibi, claiming he was elsewhere during the incident. The Regional Trial Court (RTC) found Baguio guilty beyond reasonable doubt and sentenced him to *reclusion perpetua*. The Court of Appeals (CA) affirmed the RTC’s decision in toto. Baguio appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of Rape, despite alleged inconsistencies in the victim’s testimony and the failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals convicting accused-appellant Joselito Baguio y Santos of the crime of Rape.

The Court held that the alleged inconsistencies in AAA’s testimony pertained to minor and trivial details which did not affect the core elements of the crime. Inconsistencies on minor matters may even strengthen the credibility of a witness, as they negate any suspicion of rehearsed testimony. The Court reiterated the well-entrenched doctrine that the assessment of the credibility of witnesses is best undertaken by the trial court, which had the unique opportunity to observe their demeanor, conduct, and attitude on the stand. Both the RTC and the CA found AAA’s testimony to be clear, candid, and consistent on the material points of how she was sexually assaulted. Her positive and categorical identification of the accused as the perpetrator, corroborated by medical findings, prevailed over the weak defenses of denial and alibi, which were not substantiated by clear and convincing evidence. All elements of Rape under Article 266-A were duly proven beyond reasonable doubt. Accordingly, the penalty of *reclusion perpetua* and the awarded damages were upheld.