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

FACTS:
Accused-appellant Joselito Ibarra y Bellen was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution alleged that on December 25, 2009, in Quezon City, the accused, by means of force, threat, and intimidation, had carnal knowledge of AAA, a minor below 12 years old. The Regional Trial Court (RTC) found Ibarra guilty beyond reasonable doubt 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 and that the testimonies of the victim and her mother were inconsistent.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of Rape.

RULING

No, the Court of Appeals did not err. The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals convicting Joselito Ibarra y Bellen of the crime of Rape.

The Court held that all the elements of Rape under Article 266-A were proven beyond reasonable doubt: (1) the accused had carnal knowledge of the victim; and (2) such act was accomplished through force, threat, or intimidation. The victim’s testimony was clear, convincing, and consistent with the medical findings. The Court emphasized that the testimony of a rape victim, especially a child, is accorded great weight and credibility. Minor inconsistencies in the testimonies of the victim and her mother regarding collateral matters do not undermine the core finding of rape. The defense of denial and alibi proffered by the accused-appellant, unsupported by clear and convincing evidence, cannot prevail over the positive and credible identification by the victim. The penalty of *reclusion perpetua* and the awarded damages were affirmed in accordance with prevailing jurisprudence.