GR 75506; (June, 1991) (Digest)
G.R. No. 75506 ; June 19, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOHN LLOYD SAROL y SAGANDOY, accused-appellant.
FACTS
The accused-appellant, John Lloyd Sarol, was charged with the crime of rape in an Information filed by the Provincial Fiscal. It was alleged that on the evening of April 18, 1983, in Tabuk, Kalinga-Apayao, he armed with a knife, used force and intimidation to have sexual intercourse with the 13-year-old complainant, Judith Reyes, against her will. After trial, the court found him guilty and sentenced him to reclusion perpetua. On appeal, Sarol raised several errors, including a challenge to the trial court’s jurisdiction. He argued that the court did not acquire jurisdiction because the prosecution was not based on a valid complaint, as required under Article 344 of the Revised Penal Code for the crime of rape.
ISSUE
The primary issue resolved was whether the trial court acquired jurisdiction over the case given the accused’s contention that the complaint filed was insufficient.
RULING
The Supreme Court affirmed the conviction and held that the trial court validly acquired jurisdiction. The Court ruled that the complaint subscribed by Judith Reyes and her father was sufficient. Citing People v. Ilarde, the Court reiterated that a complaint is sufficient if it states the names of the accused, the designation of the offense, the acts complained of, the name of the offended party, the approximate time, and the place of commission. The filed complaint, which incorporated by reference the detailed sworn statement of the victim, met all these requirements. The sworn statement itself clearly narrated the facts constituting the offense. The Court further explained that the complaint need not itself contain a detailed narration; it is sufficient that the essential facts are found in an attached sworn statement which is made an integral part of the complaint. Therefore, the jurisdictional requirement was satisfied. The Court also found the victim’s testimony to be clear, convincing, and credible, outweighing the alleged inconsistencies raised by the defense. The penalty was affirmed with a modification increasing the moral damages.