PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BARTOLOME y GARCIA, Accused-Appellant. G.R. No. 191726 , February 6, 2012.

FACTS:
Accused-appellant Joselito Bartolome was charged with the crime of rape under Article 266-A of the Revised Penal Code. The prosecution’s case rested primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Bartolome, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed the defense of denial and alibi, claiming Bartolome was elsewhere at the time. The Regional Trial Court (RTC) found Bartolome guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of rape based on the testimony of the private complainant.

RULING

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

The appeal is bereft of merit. In reviewing rape cases, the Supreme Court accords great weight and respect to the trial court’s assessment of the credibility of witnesses, especially the victim, as it had the direct opportunity to observe their demeanor and deportment on the stand. The factual findings of the trial court, when affirmed by the CA, are generally binding and conclusive.

In this case, the testimony of AAA was clear, candid, and consistent on material points. She provided a straightforward and convincing narration of how the accused-appellant sexually assaulted her. The Court found no ill motive on her part to falsely accuse the appellant of such a grave crime. Minor inconsistencies in her testimony, referring to collateral matters, do not undermine her credibility but rather enhance it by negating any suspicion of rehearsed testimony.

The defense of denial and alibi, inherently weak and self-serving, cannot prevail over the positive and categorical identification made by the victim. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. Accused-appellant failed to establish physical impossibility.

All the elements of rape under Article 266-A(1) were proven beyond reasonable doubt: (1) the accused had carnal knowledge of the victim; and (2) such act was accomplished through force, threat, or intimidation. The penalty of *reclusion perpetua* was correctly imposed. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the victim, in line with prevailing jurisprudence.