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

FACTS:
Accused-appellant Joselito Ibarra y Gonzales 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, who was 13 years old at the time of the incident. AAA testified that Ibarra, a neighbor, forcibly had sexual intercourse with her inside his house. The defense, on the other hand, interposed denial and alibi, claiming Ibarra was elsewhere during the alleged incident. 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 in toto. Ibarra appealed to the Supreme Court.

ISSUE

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

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals convicting accused-appellant Joselito Ibarra y Gonzales of the crime of Rape.

The Court held that the findings of the trial court on the credibility of witnesses, especially in rape cases, are accorded great weight and respect, as it had the direct opportunity to observe the witnesses’ demeanor and manner of testifying. The testimony of AAA was found to be clear, candid, straightforward, and consistent on material points, thereby passing the test of credibility. The Court emphasized that when a young girl’s testimony on a degrading matter like rape is offered, it is unlikely that she would concoct a story that would expose herself and her family to shame and embarrassment unless it was the truth. The defense of denial and alibi, being inherently weak, cannot prevail over the positive and credible testimony of the victim. The elements of rape under Article 266-A were sufficiently proven: (1) carnal knowledge took place, and (2) it was done through force or intimidation. The Court also affirmed the award of damages, including civil indemnity, moral damages, and exemplary damages, in accordance with prevailing jurisprudence.