PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO IBARRA y GONZALES, Accused-Appellant.
G.R. No. 191752, February 6, 2013

FACTS

Accused-appellant Joselito Ibarra 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 alleged incident. AAA testified that Ibarra, her neighbor, forcibly had sexual intercourse with her inside his house. The defense, on the other hand, interposed denial and alibi, claiming Ibarra was elsewhere at the time. The Regional Trial Court (RTC) convicted Ibarra of rape and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Ibarra appealed to the Supreme Court.

ISSUE

Whether the guilt of accused-appellant Joselito Ibarra for the crime of rape has been proven beyond reasonable doubt.

RULING

NO. The Supreme Court ACQUITTED accused-appellant Joselito Ibarra on the ground of reasonable doubt.

The Court emphasized that in rape cases, the conviction of the accused must rest on the strength of the prosecution’s evidence and not on the weakness of the defense. The testimony of the complainant must be scrutinized with extreme caution and must be credible, natural, convincing, and consistent with human nature and the normal course of things.

In this case, the Court found the testimony of AAA fraught with serious inconsistencies and improbabilities that eroded her credibility. Key inconsistencies pertained to material details such as: (1) the manner by which she was allegedly dragged inside the house, (2) the specific location and position during the sexual act, (3) the presence or absence of other people in the vicinity, and (4) her conduct immediately after the alleged incident. The Court noted that her narrative did not reflect the natural behavioral response expected from a victim of such a violent crime. Furthermore, no medical examination was conducted to corroborate her claim of recent sexual intercourse or physical trauma.

The Court held that when the testimony of a rape victim is inconsistent and improbable, it cannot be the sole basis for conviction. The prosecution failed to discharge its burden of proving Ibarra’s guilt beyond reasonable doubt. The constitutional presumption of innocence therefore prevails. Joselito Ibarra was ordered immediately released from custody unless he is being held for another lawful cause.