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 has been proven beyond reasonable doubt.

RULING

NO. The accused is ACQUITTED on the ground of reasonable doubt. The Supreme Court reversed the convictions. While the Court acknowledged that the testimony of a rape victim, especially a minor, is normally accorded great weight, the prosecution’s evidence in this case failed to meet the required quantum of proof. The Court found several material and significant inconsistencies in AAA’s testimony regarding the details of the alleged assault, which eroded her credibility. These inconsistencies pertained to the sequence of events, the manner by which the accused allegedly entered the room, and the specific acts committed. The Court emphasized that in criminal cases, the conviction of the accused must rest on the strength of the prosecution’s evidence and not on the weakness of the defense. When the testimony of the complainant is fraught with inconsistencies casting doubt on its veracity, the accused must be acquitted. The constitutional presumption of innocence prevailed.