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 forcibly had sexual intercourse with her. The defense interposed denial and alibi, claiming the accused was elsewhere at the time of the alleged crime. The Regional Trial Court convicted Bartolome of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. The case was elevated to the Supreme Court via automatic review.

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 reversed the decisions of the lower courts.

The Court meticulously reviewed the evidence and found the testimony of the private complainant to be replete with inconsistencies and irreconcilable contradictions on material points. These pertained to the sequence of events, the manner by which the accused allegedly entered her room, the presence and location of other persons in the house during the incident, and her actions immediately after the alleged rape. The inconsistencies were not minor but struck at the very core of the narrative, casting serious doubt on its credibility.

The Court emphasized the fundamental principle that in rape cases, the accusation must be supported by credible and convincing evidence. The testimony of the complainant must be scrutinized with extreme caution, and her credibility must be established beyond reasonable doubt. When the testimony is fraught with inconsistencies, the doubt created must be resolved in favor of the accused. The constitutional presumption of innocence prevails unless overturned by proof beyond reasonable doubt. In this case, the prosecution failed to meet this stringent burden of proof. Consequently, the Court acquitted Joselito Bartolome and ordered his immediate release from detention, unless he is held for another lawful cause.