GR 124453; (March, 2000) (Digest)
G.R. No. 124453 ; March 15, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSEPH PAMBID y CORNELIO, accused-appellant.
FACTS
The accused-appellant, Joseph Pambid, was charged with two counts of statutory rape against Maricon Delvie Grifaldia, a six-year-old neighbor. The prosecution alleged that between April and May 1993, Pambid twice sexually assaulted the victim. The first incident occurred at knifepoint in his house, and the second in his aunt’s adjacent house. The victim did not immediately report the rapes due to threats. The crimes were revealed weeks later when the child spontaneously disclosed the assaults to her mother and aunt. A medico-legal examination confirmed the victim was in a non-virgin state, with a deep, healed hymenal laceration.
The defense presented denial, alibi, and a plea of insanity through the testimonies of the accused’s parents, who claimed he was not present at the locus criminis during the alleged period. A psychiatrist testified the accused had a low IQ and was mentally deficient, but found him to be oriented and without psychosis. The trial court convicted Pambid on both counts and sentenced him to reclusion perpetua for each.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt.
RULING
The Supreme Court modified the trial court’s decision, convicting the accused of only one count of rape. The Court affirmed the conviction for the second incident, finding the victim’s testimony for that event to be clear, candid, and consistent. The testimony withstood the test of rigorous cross-examination and was consistent with the medico-legal findings, which corroborated the sexual abuse. The defense of alibi and denial, uncorroborated and coming solely from the accused’s parents, could not prevail over the positive identification by the victim.
However, the Court acquitted the accused of the first alleged rape. The information charged him with two counts “on or about the period comprising April and May, 1993,” without specifying distinct dates. This constituted a duplicitous complaint, as it charged more than one offense in a single count, violating the accused’s constitutional right to be informed of the nature and cause of the accusation against him. While the victim testified to two incidents, the defective information warranted conviction only for the offense proven which was clearly described and established—the second rape. The penalty of reclusion perpetua was upheld, and civil indemnity and moral damages were awarded to the victim.