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 was proven beyond reasonable doubt.

RULING

NO. The accused is ACQUITTED on the ground of reasonable doubt. The Supreme Court reversed the convictions. While the Court acknowledged the gravity of the charge, it found that the prosecution failed to prove the accused’s guilt with the required moral certainty. The Court identified several material inconsistencies and improbabilities in AAA’s testimony that eroded its credibility. Notably, her account of how the accused entered her locked room was unclear and shifting. Furthermore, her behavior immediately after the alleged rapesuch as not immediately reporting the incident to her relatives who were in the very same housewas deemed contrary to human experience and ordinary behavior of a rape victim. The testimony of the medico-legal officer also did not provide conclusive physical evidence of recent sexual intercourse or force. In light of these serious doubts regarding the truthfulness of the complainant’s narrative, the presumption of innocence must prevail. The Court emphasized that while the testimony of a rape victim is often sufficient for conviction, it must still pass the test of credibility and be consistent with human nature and the normal course of things. Where such testimony is fraught with doubts, an acquittal is imperative.