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 relied primarily on the testimony of the private complainant, AAA, a minor. AAA testified that on the night of the incident, the accused, who was her neighbor and the common-law partner of her aunt, entered her room while she was sleeping, covered her mouth, threatened her with a knife, and sexually assaulted her. The defense interposed denial and alibi, claiming the accused was elsewhere at the time of the alleged crime.

ISSUE

Whether the guilt of the accused for the crime of rape has been proven beyond reasonable doubt.

RULING

NO. The accused is ACQUITTED on the ground of reasonable doubt. The Supreme Court found the testimony of the private complainant, AAA, to be fraught with serious inconsistencies and irreconcilable contradictions regarding material points of the incident. These pertained to the manner and sequence of how the accused allegedly entered her room, the specific threats made, the position she was in during the assault, and the presence or absence of a weapon. The Court emphasized that while the testimony of a rape victim is normally accorded great weight, it must still pass the test of credibility. In this case, the inconsistencies were not minor but struck at the very core of the narrative, casting doubt on its truthfulness. The defense of denial and alibi, while inherently weak, gains strength where the prosecution’s evidence is itself weak and insufficient to prove guilt beyond reasonable doubt. Consequently, the constitutional presumption of innocence prevails, and the accused must be acquitted.