**Facts:**
– **April 24, 1994:** Mary Grace Jamisola, 14, is alone at home when Toribio Galido enters while she is wrapped in a towel after a bath. He binds her hands and mouth, threatens her with a bladed weapon, and rapes her.
– **January 7, 1996:** Mary Grace is again alone at home. Galido enters, threatens her with a blade, pushes her against a wall, and sexually assaults her.
– **May 16, 1996:** As Mary Grace walks home from a fiesta, Galido follows her into the woods, subdues her, and rapes her again.
– **August 8, 1996:** Galido attempts to rape Mary Grace while she sleeps. A family member awakens, causing Galido to flee.
– **August 9, 1996:** Mary Grace and her mother report the incidents to authorities. Mary Grace undergoes medical examination, which corroborates her account with findings of healed lacerations indicative of sexual abuse.
Galido was charged with three counts of rape and one count of light threats. During his arraignment, he pled not guilty. His defenses included alibi and a claim of false accusations due to personal grudges.
**Procedural Posture:**
– Galido was convicted by the RTC of Sorsogon, Sorsogon, Branch 53, for three counts of rape and one count of light threats, resulting in three life sentences and 30 days of arrest.
– He appealed, arguing defective information regarding the description of force and credibility of the victim’s testimony.
**Issues:**
1. Whether the omission of “force or intimidation” in the Informations invalidated the charges.
2. Whether Mary Grace’s testimony was credible and sufficient to sustain a conviction.
**Court’s Decision:**
1. **Defective Information Issue:**
– The Court held that while the Informations lacked explicit reference to “force or intimidation,” the omission was non-fatal. The original complaints, which were made available to Galido, clearly accused him of rape through “force and intimidation.”
– The RTC relied on competent evidence presented during the trial that proved the use of force and intimidation, thus curing any informational defect.
– The failure of Galido to initially object to the sufficiency of the Information or the admission of evidence asserting force or intimidation waived his right to contest these on appeal.
2. **Credibility of Testimony:**
– The Court upheld the credibility of Mary Grace’s testimony, citing her clear, consistent, and candid recounting of events, complemented by medical findings.
– The principle that trial courts have the best opportunity to observe witness demeanor was emphasized.
– Reinforced by her spontaneous and straightforward responses under cross-examination, Mary Grace’s detailed descriptions of the assaults were considered truthful.
– The medico-legal findings corroborated her account, establishing physical evidence consistent with repeated sexual abuse.
**Doctrine:**
– **Doctrine of Cured Defect in Information:** An information’s failure to explicitly state an element of the crime can be cured by unobjected evidence presented during trial, provided the defendant had knowledge of the essential details from prior complaints.
– **Doctrine of Witness Credibility:** The consistent, positive testimony of a rape victim, especially if corroborated by medical evidence, can be sufficient for conviction even if the descriptions of multiple incidents appear similar.
**Class Notes:**
– **Key Elements of Rape (Art. 266-A RPC):** Carnal knowledge against the victim’s will through force, threat, or intimidation.
– **Alibi and Credibility:** Alibi must prove the physical impossibility of presence at the crime scene; the credibility of a rape victim is often paramount, especially when her account is consistent and corroborated.
– **Relevant Provisions:** Revised Penal Code Articles 266-A (Rape) and 285 (Light Threats).
**Historical Background:**
– The case reflects the 1997 amendments to the Revised Penal Code on rape, highlighting increased judicial sensitivity to victims’ testimonies and medical corroborations.
– The context includes ongoing societal challenges regarding the prosecution of rape cases in the Philippines, leading to stringent judicial assessments of evidence and credibility.
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