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 12 years old at the time of the alleged incident. AAA testified that Bartolome, a 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 accused-appellant Joselito Bartolome 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, especially a minor, is given great weight. The alleged inconsistencies in AAA’s testimony referred to minor details and did not affect the core elements of the crime. The Court emphasized that a young girl would not ordinarily concoct a story of defloration, undergo the ordeal of a public trial, and endure the stigma attached to rape victims unless she was truly motivated by a desire to have the wrongdoer punished.

Regarding the lack of medical evidence, the Court ruled that it is not indispensable for a conviction. The medical examination, while corroborative, is not an element of the crime of rape. The victim’s credible and categorical testimony, standing alone, is sufficient to establish guilt beyond reasonable doubt. The elements of rape under Article 266-A were duly proven: (1) Bartolome had carnal knowledge of AAA; and (2) such act was accomplished through force or intimidation. The defense of denial and alibi, unsupported by clear and convincing evidence, cannot prevail over the positive identification by the victim.

The Supreme Court affirmed the decision of the Court of Appeals in toto, upholding the penalty of reclusion perpetua and the awards of civil indemnity, moral damages, and exemplary damages.