PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726 , February 6, 2012.

FACTS:
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, a minor. AAA testified that on the night of the incident, the accused, who was her neighbor and the common-law partner of her aunt, entered her room while she was sleeping, covered her mouth, threatened her with a knife, and sexually assaulted her. The defense interposed denial and alibi, claiming the accused was elsewhere at the time. The Regional Trial Court convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. The case was elevated to the Supreme Court via automatic review.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

NO. The accused is ACQUITTED on the ground of reasonable doubt. The Supreme Court reversed the convictions. While the Court acknowledged that the testimony of a rape victim, especially a minor, is normally accorded great weight, it found that the prosecution failed to establish the guilt of the accused with the required moral certainty. The Court identified several material inconsistencies and improbabilities in AAA’s testimony regarding the details of the alleged assault, the presence of other people in the house, and her actions immediately after the incident. These inconsistencies pertained not to trivial matters but to significant details that cast doubt on the veracity of the narrative. Furthermore, the Court noted the lack of credible corroborative evidence and the failure of the prosecution to explain these material inconsistencies. In criminal cases, the burden of proof lies with the prosecution, and any doubt is resolved in favor of the accused. Consequently, the Court held that the evidence did not overcome the constitutional presumption of innocence. Joselito Bartolome was ordered immediately released from custody unless detained for another lawful cause.