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. 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 was proven beyond reasonable doubt.

RULING

NO. The accused-appellant is ACQUITTED 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, 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 several material and significant inconsistencies in AAA’s testimony that eroded its credibility. These pertained to the sequence of events, the manner by which the accused allegedly entered the room, the presence of other people in the house, and her actions immediately after the alleged rape. The inconsistencies were not minor but touched upon the very essence of the offense and cast doubt on whether the crime indeed occurred. When the testimony of the complainant is fraught with inconsistencies and does not inspire belief, the accused must be acquitted. The constitutional presumption of innocence prevails, and the prosecution failed to discharge its burden of proving guilt beyond reasonable doubt. Accordingly, the Court reversed the decisions of the lower courts and ordered the immediate release of the accused-appellant unless he is detained for another lawful cause.