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 rested primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Bartolome, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Bartolome 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. Bartolome appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly questioning AAA’s credibility and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape, despite alleged inconsistencies in the victim’s testimony and the absence of medical evidence.

RULING

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

The Court held that the testimony of a rape victim, if credible, is sufficient to support a conviction. Inconsistencies on minor details do not impair credibility but may even enhance it by showing the testimony was not rehearsed. The Court found AAA’s testimony to be straightforward, candid, and consistent on the material points of the crimethe sexual assault and the force employed. Her young age and the traumatic nature of the experience were considered. The defense of denial and alibi, unsupported by clear and convincing evidence, cannot prevail over the positive identification by the victim. The absence of medical evidence is not fatal to the prosecution’s case, as the commission of rape is not dependent on physical evidence but on the credible testimony of the victim. All elements of rape under Article 266-A were duly proven beyond reasonable doubt. The penalty of *reclusion perpetua* was affirmed, and the accused-appellant was ordered to pay civil indemnity, moral damages, and exemplary damages.