PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant. G.R. No. 191250, June 6, 2011.

FACTS:
Accused-appellant Joselito Ibarra was charged with the crime of rape committed against his 13-year-old daughter, AAA. The prosecution presented AAA’s testimony detailing how her father, on two separate occasions, had sexual intercourse with her through force and intimidation. The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents. The Regional Trial Court convicted Ibarra of two counts of rape and sentenced him to death. On automatic review, the case was transferred to the Court of Appeals, which affirmed the conviction but modified the penalty to *reclusion perpetua* in line with the abolition of the death penalty under Republic Act No. 9346 .

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for two counts of rape based on the credibility of the victim’s testimony.

RULING

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

The Court upheld the findings of the trial court and the Court of Appeals, giving utmost respect to their assessment of witness credibility, especially in rape cases. The victim’s testimony was found to be clear, candid, and consistent on material points, thereby passing the test of credibility. The Court emphasized that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. Denial and alibi, which are inherently weak defenses, cannot prevail over the positive and credible identification by the victim. The Court also noted that the relationship between the accused and the victim (father-daughter) made the crime even more reprehensible, as it constituted a betrayal of parental authority and trust. The penalty of *reclusion perpetua* for each count of rape was affirmed, with the corresponding civil liabilities.