G.R. No. 138033 . January 30, 2007.
Renato Baleros, Jr. vs. People of the Philippines.

FACTS

Petitioner Renato Baleros, Jr. was charged with attempted rape under an Information alleging that he forcefully covered the face of Martina Lourdes T. Albano with a cloth soaked in a chemical, lay on top of her with intent to have carnal knowledge, but was unable to complete all acts of execution due to a cause other than his own desistance. The Supreme Court, in a prior Decision, acquitted him of attempted rape but convicted him of the lesser crime of light coercion (unjust vexation) under Article 287 of the Revised Penal Code. Baleros filed a Motion for Partial Reconsideration, seeking complete acquittal.
He argued that his conviction for light coercion under an Information exclusively for attempted rape contravened the ruling in People v. Contreras, where the Court held an accused could not be convicted of unjust vexation under an information for statutory rape, as the elements of the former do not form part of the latter crime and were not alleged.

ISSUE

Whether the petitioner can be validly convicted of the crime of light coercion (unjust vexation) under an Information specifically charging him with attempted rape.

RULING

Yes. The Supreme Court denied the motion, holding the conviction for light coercion was proper. The Court distinguished the present case from Contreras. In Contreras, the Informations for statutory rape contained no averments constituting the elements of unjust vexation. Here, the Information for attempted rape contained detailed factual allegations—the act of forcefully covering the victim’s face with a chemically soaked cloth and lying on top of her—which constitute acts causing annoyance, irritation, torment, distress, or disturbance to the victim.
These factual averments fully apprised the petitioner of the nature of the accusation against him, satisfying his constitutional right to be informed. The Court emphasized that unjust vexation is a broad concept encompassing any human conduct that unjustly annoys or irritates an innocent person, and it does not require the specific allegation of malice, compulsion, or restraint in the Information. The victim’s distress was evident from her reaction after the incident and her act of filing the case. Thus, the facts alleged in the Information, while insufficient for attempted rape, sufficiently constituted the crime of unjust vexation.