PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA Y PANCHO, Accused-Appellant. G.R. No. 191050. January 25, 2012.

DOCTRINE: The crime of rape is consummated by the slightest penetration of the female organ. Full penetration or rupture of the hymen is not required. The testimony of a credible, consistent, and categorical child victim is given great weight and is sufficient to sustain a conviction.

FACTS

On June 26, 2004, in Quezon City, accused-appellant Joselito Ibarra, the common-law spouse of AAA’s mother, raped his 11-year-old stepdaughter, AAA. The incident occurred inside their house while AAA’s mother was at work. Ibarra entered AAA’s room, covered her mouth, threatened to kill her if she shouted, removed her shorts and panty, and then inserted his penis into her vagina. AAA felt pain and cried. Ibarra then warned her not to tell anyone. AAA eventually reported the rape to her aunt and subsequently to the authorities. A medical examination revealed healed hymenal lacerations, consistent with a history of sexual intercourse. Ibarra was charged with rape under Article 266-A of the Revised Penal Code. The Regional Trial Court convicted Ibarra of qualified rape and sentenced him to death. The case was automatically elevated to the Supreme Court for review due to the death penalty imposed.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Joselito Ibarra for the crime of qualified rape.

RULING

No, the Supreme Court affirmed the conviction but modified the penalty. The Court held that all elements of rape were proven beyond reasonable doubt: (1) Ibarra had carnal knowledge of AAA; (2) AAA was under 12 years of age at the time; and (3) Ibarra is AAA’s stepfather, a qualifying circumstance under the law. The Court gave full credence to AAA’s clear, candid, and consistent testimony, which withstood rigorous cross-examination. The Court emphasized that in rape cases, the victim’s testimony is the single most important evidence, especially when the victim is a minor. The medical finding of *healed* lacerations did not negate the rape but was consistent with AAA’s account that the incident happened weeks before the examination. The defense of denial and alibi was weak and uncorroborated. However, due to the passage of Republic Act No. 9346 prohibiting the death penalty, the Supreme Court modified the penalty to *reclusion perpetua* without eligibility for parole. The Court also increased the awards of civil indemnity, moral damages, and exemplary damages.