G.R. No. 144495-96 March 12, 2002
PEOPLE OF THE PHILIPPINES, appellee, vs. LEONARDO S. PASCUAL, appellant.

FACTS

The appellant, Leonardo S. Pascual, was convicted by the Regional Trial Court of Laoag City of two counts of rape committed against his then 14-year-old daughter, Virginia. The first incident allegedly occurred in June 1997, where the appellant, armed with a knife, sent Virginia’s younger sister away, covered Virginia’s mouth with a pillow, and forcibly had carnal knowledge of her. The second incident took place in August 1997, where the appellant entered the room where Virginia slept with her sisters, laid beside her, and again raped her. The victim testified to the force, intimidation, and threats used by her father, including a warning that he would kill her if she revealed the assaults. Her testimony was corroborated by medical findings of old healed hymenal lacerations consistent with sexual intercourse. The defense consisted of a denial and an alibi, claiming the charges were fabricated due to family resentment.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for two counts of rape beyond reasonable doubt, particularly in light of the defense’s challenge to the victim’s credibility and the alleged vagueness of the dates in the informations.

RULING

The Supreme Court affirmed the conviction. The Court held that the testimony of a rape victim, if credible and consistent, is sufficient to sustain a conviction. It found Virginia’s narration of the incidents to be straightforward, candid, and consistent with human experience, thereby passing the test of credibility. The detailed account of the use of a knife, the covering of her mouth, the sending away of her sister, and the subsequent threats rendered her testimony highly credible and convincing. The medical evidence provided physical corroboration. The Court further ruled that the exact date of the commission of rape is not an essential element of the crime; it is sufficient that the information alleges that the offense was committed at a time as near as possible to the actual date. The failure to specify the exact dates in the informations did not prejudice the appellant’s right to prepare his defense, as the victim testified to the specific months and circumstances, which the defense was able to confront. The defense of denial and alibi, unsubstantiated by clear and convincing evidence, could not prevail over the positive and credible identification by the victim. Thus, the guilt of the appellant was established beyond reasonable doubt.