PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 191752, April 25, 2012

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, had sexual intercourse with her through force and intimidation. The defense interposed denial and alibi, claiming AAA was coerced by her mother to fabricate the charges. The Regional Trial Court (RTC) found Ibarra guilty of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape.

RULING

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

The appeal primarily challenged the credibility of the victim’s testimony. The Court reiterated the well-established doctrine that in rape cases, the credibility of the complainant is of primordial importance. The trial court’s assessment of credibility is accorded great weight and respect, as it had the direct opportunity to observe the witnesses’ demeanor and manner of testifying. AAA’s testimony was found to be clear, candid, consistent, and unwavering on material points, thereby passing the test of credibility. Her detailed account of the harrowing incidents, including the use of force and threats, was credible and sufficient to establish the elements of rape.

The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and categorical testimony of the victim. The alleged ill-motive of the mother was not proven and does not detract from the credibility of AAA’s direct account of the crimes. All elements of rape under Article 266-A of the Revised Penal Code were duly proven: (1) sexual congress; (2) accomplished through force or intimidation; (3) with the victim under 12 years of age or demented at the time. The Court also affirmed the award of damages, modifying them in accordance with prevailing jurisprudence to P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages for each count of rape.