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

FACTS: Joselito Ibarra y Gonzales 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 Pasig City, the accused, by means of force, threat, and intimidation, had carnal knowledge of the victim, 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 witnesses were inconsistent.

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 testimonies of the prosecution witnesses and the failure of the prosecution to prove guilt beyond reasonable doubt.

RULING

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

The Court held that minor inconsistencies in the testimonies of witnesses, particularly on trivial matters, do not undermine their credibility but rather enhance it by negating any suspicion of rehearsed testimony. The core elements of the crime of rape were sufficiently proven: (1) sexual intercourse took place; (2) it was accomplished through force, threat, or intimidation; and (3) the victim was under 12 years of age at the time. The victim’s categorical, straightforward, and consistent testimony, corroborated by medical findings, was given full weight and credit. The defense of denial and alibi, unsupported by clear and convincing evidence, cannot prevail over the positive identification by the victim. The Supreme Court thus affirmed the decision of the Court of Appeals, with modifications to the awarded damages in accordance with prevailing jurisprudence.