People of the Philippines vs. XXX

A rape victim's lone, uncorroborated testimony is sufficient to sustain a conviction for rape, provided that the testimony is clear, convincing, and otherwise consistent with human nature. In incestuous rape, proof of force and violence is not even essential because the moral and physical ascendancy of the father over his daughter is sufficient to cow her into submission. However, an Information that approximates the time of the commission of the offense over a span of multiple years is egregiously defective, as it deprives the accused of the constitutional right to be informed of the nature and cause of the accusation, although such defect may be deemed waived if not raised before arraignment.

The accused-appellant is the biological father of the victim, AAA, who was born in 1981. The family, including the victim's mother and two siblings, lived together in a house in Apalit, Pampanga, where they all slept together in one big room. The case involves charges of incestuous rape filed against the father, with the prosecution invoking the constitutional right of the accused to be informed of the nature and cause of the accusation against him, as well as the statutory framework under the Revised Penal Code and the Rules of Criminal Procedure governing the sufficiency of Informations.

The accused-appellant XXX is the biological father of AAA, who was born in 1981. The family, composed of the accused-appellant, the victim, her mother, and two siblings, lived together in a house in Apalit, Pampanga, where they all slept together in one big room.

Sometime in June 1995, at around 10:00 p.m., the victim, then thirteen years old, was sleeping in their house with the accused-appellant and her mother when she was suddenly carried by the accused-appellant and placed beside him. The accused-appellant undressed the victim and himself, started kissing her, and inserted his penis inside her vagina. The victim could not resist because the accused-appellant punched and slapped her. After the assault, the accused-appellant ordered the victim not to tell anybody and threatened to kill her mother. Two days thereafter, the same incident happened again, with the accused-appellant removing the victim's panty and inserting his penis inside her vagina. When the victim tried to resist and pushed him away, the accused-appellant punched her in the left arm and shoulder and threatened to kill her mother if she resisted. The victim claimed that the same incident happened again after three days, and again four days later.

The last incident happened in October 1999, at around 10:00 p.m., when the victim was about to sleep. The accused-appellant removed the victim's underwear, laid on top of her, and inserted his penis inside her vagina while threatening to kill her mother if she resisted. In December 1999, the victim discovered she was two months pregnant, which prompted her to tell her mother about the incidents. The victim and her mother then went to the police station to report the matter. On January 14, 2000, the victim underwent a medical examination with Dra. Cabugawan, who issued a Medical Certificate stating that the victim was no longer a virgin, that her uterus was enlarged to two to three months size, and concluding that she was two to three months pregnant. A month later, the victim suffered a miscarriage.

The accused-appellant relied on denial to establish his innocence, testifying that the victim's allegations were not true. He pointed to a misunderstanding between him and his daughter regarding her 18th birthday as the reason she would falsely accuse him. The accused-appellant testified that the victim wanted a cotillion or debut party for her 18th birthday, but he could not afford it because he was poor. He also claimed that the victim started going out with a male friend named Fernando, who was courting her, and that there may have been an intimate relation between them.

• Sufficiency of Prosecution Evidence: The People, as plaintiff-appellee, argued that the prosecution was able to sufficiently prove the elements of the crimes charged, relying on the victim's clear, convincing, and consistent testimony establishing carnal knowledge through force and intimidation.
• Credibility of the Victim's Testimony: The People maintained that the trial court's findings on the credibility of the victim's testimony deserve great weight and should not be disturbed on appeal, given the trial court's first-hand opportunity to observe the witnesses' demeanor.

• Denial and Motive to Fabricate: Accused-appellant argued that he did not commit the crimes charged, relying on denial and alleging that the victim concocted the rape allegations because he was not able to give her the birthday party she wanted for her 18th birthday.
• Questioning the Victim's Motive: Accused-appellant pointed to a misunderstanding with his daughter regarding her debut party and her relationship with a male friend named Fernando as reasons for the false accusation.

• Sufficiency of Evidence for Conviction: Whether the RTC and the CA erred in convicting accused-appellant of two counts of Qualified Rape and one count of Simple Rape.
• Defectiveness of the Information: Whether the Information in Criminal Case No. 00-2603(M), which alleged the crime occurred between June 1995 and October 1999, was defective for failing to specify the exact date of the commission of the offense.

• Sufficiency of Evidence for Conviction: No. The prosecution sufficiently proved the elements of rape by sexual intercourse — carnal knowledge and the use of force or intimidation — through the victim's clear, convincing, and consistent testimony, which was entitled to great weight given the incestuous relationship.
• Defectiveness of the Information: Yes, the Information was egregiously defective for approximating the commission of the crime over a span of more than four years, but the defect was deemed waived because accused-appellant failed to file a motion to quash or a motion for bill of particulars before arraignment.

• Sufficiency of Evidence for Conviction: The Court held that the two elements of rape by sexual intercourse — (1) that the offender had carnal knowledge of the girl, and (2) that such act was accomplished through the use of force or intimidation — were both present as duly proven by the prosecution. The victim testified in detail how the accused-appellant committed the sexual abuses, and this testimony was given weight and credence by both the RTC and the CA. In rape cases, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that the latter's testimony is clear, convincing, and otherwise consistent with human nature. The trial court's findings on credibility carry great weight because the trial court had the first-hand opportunity to hear the testimonies of the witnesses and observe their demeanor, conduct, and attitude during cross-examination. The Court also noted that in incestuous rape, proof of force and violence is not even essential because the moral and physical ascendancy of the father over his daughter is sufficient to cow her into submission. The accused-appellant's denial was held to be an inherently weak defense that cannot prevail over the positive and credible testimony of the prosecution witness. The Court found it inconceivable that a minor would undergo an invasive medical examination, execute a sworn affidavit, and testify in court against her own father just to exact revenge over the absence of a birthday party, especially since the allegations involved at least three separate incidents of abuse, the last of which resulted in the victim's impregnation.

• Defectiveness of the Information: The Court reminded prosecutors of their duty to state with particularity the offense charged in the Informations they file. While the failure to specify the exact date or time when the rape was committed does not ipso facto render the Information defective, as neither the date nor the time of the commission of rape is a material ingredient of the crime, an Information that approximates the date and time of the commission of the offense within the span of multiple years does not fulfill the purpose of an Information, which is to comply with the constitutional right of the accused to be informed of the nature and cause of the accusation against him. The Court cited prior jurisprudence holding that a statement of time so general as to span a number of years is fatally defective because it deprives the accused of the opportunity to prepare his defense. In this case, the Information in Criminal Case No. 00-2603(M) asked the accused-appellant to account for his activities for around 1,600 days, especially since his defense hinged on denial. The Court held that the Information was egregiously defective, saved only by the accused-appellant's implied waiver to raise the defect. The Court also reminded trial courts of their duty and power to motu proprio order the amendment of an Information should it appear to be defective, citing Section 19, Rule 119 of the Rules of Criminal Procedure.

• Lone testimony of the rape victim — In rape cases, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that the latter's testimony is clear, convincing, and otherwise consistent with human nature. The Court applied this doctrine in affirming the conviction, holding that the victim's detailed testimony established carnal knowledge through force and intimidation.
• Moral ascendancy in incestuous rape — In rapes committed by a father against his own daughter, proof of force and violence is not essential because the moral and physical ascendancy of the father over his daughter is sufficient to cow her into submission to his bestial desires. The Court relied on this doctrine to affirm the conviction despite the absence of evidence of physical force in some instances.
• Denial as an inherently weak defense — Denial is an inherently weak defense which cannot prevail over the positive and credible testimony of the prosecution witness that the accused committed the crime. As between a categorical testimony which has a ring of truth on one hand, and a mere denial and alibi on the other, the former is generally held to prevail.
• Sufficiency of the Information — An Information serves to comply with the constitutional right of the accused to be informed of the nature and cause of the accusation against him. While the Rules of Criminal Procedure only requires the approximate date of the commission of the crime, an Information that approximates the date and time of the commission of the offense within the span of multiple years does not fulfill the purpose of an Information and is egregiously defective, although the defect may be deemed waived if not raised before arraignment.

• "In rape cases, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that the latter's testimony is clear, convincing, and otherwise consistent with human nature." — This passage articulates the controlling standard for evaluating rape victim testimony and was central to the Court's affirmance of the conviction.
• "It must be noted that accused-appellant is not a mere stranger to the victim. He is her biological father. Settled is the rule that a rape victim's testimony against her parent is entitled to great weight since, customarily, Filipino children revere and respect their elders." — This passage explains why the victim's testimony in incestuous rape cases carries enhanced credibility, a principle the Court applied in affirming the conviction.
• "The Court simply cannot fathom how a minor would go to great lengths — be subjected to an invasive medical examination, execute a sworn affidavit, and go through the rigors of testifying in court — against her own father just to exact revenge over the absence of a birthday party." — This passage rejects the accused-appellant's defense of denial and alleged motive to fabricate, finding the alleged motive disproportionate to the severity of the accusations.
• "Truly, it cannot be said that Informations such as the one filed in Criminal Case No. 00-2603(M) could properly inform the accused of the nature and cause of the accusation against them." — This passage states the Court's finding that the Information was egregiously defective for spanning over four years, while noting the defect was waived by the accused-appellant's failure to raise it before arraignment.

• People vs. Jugueta, 783 Phil. 806 (2016) — Controlling precedent for the adjustment of damages in rape cases. The Court relied on this case to modify the awards of civil indemnity, moral damages, and exemplary damages.
• People vs. Soronio, 281 Phil. 820 (1991) — Cited for the definition of the two elements of rape by sexual intercourse: carnal knowledge and the use of force or intimidation.
• People vs. Alemania, 440 Phil. 297 (2002) — Cited for the principle that trial court findings on credibility of witnesses carry great weight and substance.
• People vs. Piosang, 710 Phil. 519 (2013) — Cited for the principle that denial is an inherently weak defense that cannot prevail over positive and credible testimony.
• People vs. Nuyok, 759 Phil. 437 (2015) — Cited for the rule that the failure to specify the exact date or time of the commission of rape does not ipso facto render the Information defective.
• Rocaberte vs. People, 271 Phil. 154 (1991) — Cited for the holding that a statement of time so general as to span a number of years is fatally defective because it deprives the accused of the opportunity to prepare his defense.
• Galvez vs. Court of Appeals, 307 Phil. 708 (1994) — Cited for the principle that trial courts have the power to motu proprio order the dismissal of the case and direct the filing of the appropriate information.
• People vs. Arcilla, 692 Phil. 40 (2012) — Cited for the imposition of interest at the rate of 6% per annum on monetary awards from the finality of the Decision.

• Article III, Section 14(2), Constitution — The constitutional right of the accused to be informed of the nature and cause of the accusation against him. The Court applied this provision in finding the Information in Criminal Case No. 00-2603(M) egregiously defective.
• Section 6, Rule 110, Rules of Criminal Procedure — Requires the approximate date of the commission of the crime for the Information to be sufficient. The Court interpreted this provision in the context of an Information spanning multiple years.
• Section 19, Rule 119, Rules of Criminal Procedure — Grants trial courts the power to motu proprio order the amendment of an Information should it appear to be defective. The Court cited this provision in reminding trial courts of their duty to be vigilant of the accused's rights.

Inting, Gaerlan, Dimaampao, and Singh, JJ., concurred.