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 rested 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, her neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Bartolome 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. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly questioning AAA’s credibility and the lack of medical evidence.

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 absence of medical evidence.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.

The Court held that in rape cases, the credibility of the victim is paramount. The testimony of a rape victim, if credible, convincing, and consistent with human nature and the normal course of things, is sufficient to support a conviction. Minor inconsistencies in AAA’s testimony regarding peripheral details do not undermine her credibility but rather enhance it by negating any suspicion of rehearsed testimony. The Court found AAA’s account of the forcible sexual assault to be straightforward, candid, and consistent on the material points of how she was threatened and violated.

Regarding the lack of medical evidence, the Court reiterated the well-established doctrine that medical examination is not indispensable in a prosecution for rape. A medical certificate is merely corroborative in nature. The crime of rape can be proven by the sole testimony of the victim, provided it meets the test of credibility. The absence of physical injuries or fresh lacerations does not disprove rape, as their presence depends on various factors. The positive and categorical testimony of AAA, who positively identified Bartolome as her assailant, prevailed over his bare denial and alibi, which are inherently weak defenses. Consequently, the Supreme Court affirmed the judgment of the Court of Appeals finding Joselito Bartolome guilty beyond reasonable doubt of the crime of rape.