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, as amended. 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, 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. On appeal to the Supreme Court, Bartolome argued, among others, that the prosecution failed to prove his guilt beyond reasonable doubt, highlighting alleged inconsistencies in AAA’s testimony.

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.

RULING

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

The Court held that minor inconsistencies in the testimony of a rape victim, particularly one who is of tender age, do not undermine her credibility. The Court emphasized that when a young girl testifies that she has been raped, she says all that is necessary to prove the commission of the crime. The alleged inconsistencies pertained to collateral matters and did not touch upon the essential elements of the crime of rape, which were sufficiently established by AAA’s clear, categorical, and consistent testimony on the fact of sexual intercourse and the use of force and intimidation. The Court reiterated the doctrine that testimonies of child-victims are given full weight and credit, as youth and immaturity are generally badges of truth. Furthermore, the defense of denial and alibi, which are inherently weak defenses, cannot prevail over the positive and credible testimony of the victim. The elements of rape under Article 266-A were proven beyond reasonable doubt. Accordingly, the Supreme Court affirmed the decision of the Court of Appeals in toto.