PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 218592. January 11, 2017.

FACTS: Joselito Ibarra y Gonzales 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, who was 12 years old at the time of the alleged incident. AAA testified that Ibarra, her stepfather, sexually assaulted her. The Regional Trial Court (RTC) convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision. Ibarra appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in AAA’s testimony and the lack of medical evidence to corroborate her claim of a torn hymen.

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 victim’s testimony and the absence of medical corroboration for her claim of a torn hymen.

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 of paramount importance. The alleged inconsistencies in AAA’s testimony pertained to minor details and did not affect the core elements of the crime. The Court emphasized that a young victim’s testimony, given her tender age, is not expected to be flawless. Furthermore, the Court ruled that medical evidence is not indispensable for a conviction of rape. The testimony of the victim, if credible, convincing, and consistent with human nature and the normal course of things, is sufficient to establish the crime. The positive and categorical identification by AAA, who had no ill motive to falsely accuse her stepfather, prevailed over Ibarra’s bare denial. The elements of rape under Article 266-A were sufficiently proven. Accordingly, the Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction and the penalty of reclusion perpetua.