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 has been proven beyond reasonable doubt.

RULING

NO, the accused’s guilt was not proven beyond reasonable doubt. The Supreme Court ACQUITTED Joselito Bartolome.
The Court emphasized that in rape cases, the conviction of the accused must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The testimony of the complainant must be scrutinized with extreme caution and must be credible, natural, convincing, and consistent with human nature and the normal course of things. In this case, the Court found AAA’s testimony fraught with inconsistencies and improbabilities regarding material points, such as the manner and sequence of how the accused allegedly entered her room, subdued her, and committed the act, which were not congruent with ordinary human experience. The testimony failed to meet the test of moral certainty and left room for reasonable doubt. When the evidence for the prosecution fails to prove the accused’s guilt beyond reasonable doubt, it is the Court’s duty to acquit. The constitutional presumption of innocence must prevail.