### Facts:
1. **Incidents**:
– **April 2001 Rape**: AAA, a minor, testified that on an afternoon in April 2001, she was raped by Noel Dion y Duque (Dion) in a secluded grassy area after he threatened her with harm.
– **June 16, 2001 Rape**: AAA testified that Dion raped her again in their kitchen late at night. Her uncle, CCC, caught Dion after hearing noises and finding him hiding in a corner.
2. **Criminal Complaints**: Two separate criminal complaints were filed against Dion on June 19, 2001, for statutory rape of a 10-year-old minor.
3. **Arraignment**: Dion requested a preliminary investigation, and after finding probable cause, he was arraigned on September 12, 2001, where he pled not guilty.
4. **RTC Proceedings**:
– **Pre-trial and Joint Trial**: Pre-trial conference was held on March 6, 2002, followed by joint trial.
– **Prosecution Evidence**: Included AAA’s testimony, a Medico-Legal Certificate showing healed hymenal lacerations, and testimonies from her grandmother and the medico-legal practitioner.
– **Defense Evidence**: Included testimonies from Dion and four other witnesses aimed to corroborate his alibi and denial.
5. **RTC Decision (Dec 21, 2004)**: Found Dion guilty of two counts of statutory rape and sentenced him to reclusion perpetua for each count.
6. **Appeal to CA**: Dion appealed, citing a defective information in one complaint and credibility concerns related to AAA’s testimony.
7. **CA Decision (July 25, 2007)**: Affirmed the RTC decision.
8. **Appeal to Supreme Court**: Raised similar issues focusing on the complaint’s validity and the credibility of AAA.
### Issues:
1. **Validity of Criminal Case No. 4355-R**: Did the information in the complaint violate Dion’s right to prepare his defense by not specifying the exact or approximate date of the offense?
2. **Credibility of AAA’s Testimony**: Was AAA’s testimony credible despite alleged improbabilities, inconsistencies, and the lack of corroborative evidence?
3. **Relevance of Medico-Legal Certificate**: Did the findings of the Medico-Legal Certificate affect the credibility of the rape allegations?
### Court’s Decision:
1. **Validity of Criminal Case No. 4355-R**:
– The Supreme Court cited Section 11, Rule 110 of the Revised Rules of Criminal Procedure, emphasizing that the exact date of commission does not have to be included unless it is a material ingredient of the offense.
– Held that in statutory rape, the date is not a material element as long as the minor’s age and occurrence of rape are sufficiently proven.
2. **Credibility of AAA’s Testimony**:
– Affirmed the credibility of AAA’s testimony, highlighting that minor inconsistencies do not detract from the overall veracity.
– Reiterated that the trial court’s assessment of witness credibility is given great deference as it has the advantage of observing the witness firsthand.
3. **Relevance of Medico-Legal Certificate**:
– Upheld that the Medico-Legal Certificate is corroborative and not indispensable for a rape conviction.
– Emphasized that penetration, not ejaculation or presence of sperm, constitutes rape.
### Doctrine:
1. **Rule on Date Specification in Sexual Assault Cases**: The precise date of the commission of the offense need not be stated unless it is a material ingredient.
2. **Credibility over Minor Inconsistencies**: Testimony of a rape victim, particularly a minor, is given weight even with minor inconsistencies as these do not necessarily impair credibility.
3. **Role of Medico-Legal Certificates in Rape Cases**: Medico-legal findings are corroborative and not essential for conviction; rape can be substantiated based on the credibility of the victim’s testimony alone.
### Class Notes:
1. **Elements of Statutory Rape**:
– **Victim’s Age**: Under 12 years old.
– **Act**: Carnal knowledge.
– **No Need for Force/Intimidation**: The minor’s age itself negates the necessity for proving force or intimidation.
2. **Legal Provisions**:
– **Revised Penal Code**: Article 266-A, paragraph 1(d) on rape; Article 266-B on penalties.
– **Rules of Criminal Procedure**: Section 11, Rule 110 on date of commission of the offense.
3. **Application in Case**:
– **Credibility Determination**: Court’s discretion in evaluating the consistency and demeanor of witnesses.
– **Documentary Evidence**: Supporting documents must be properly authenticated to be given probative value.
### Historical Background:
– This case reiterates the Philippine judiciary’s stance on the credibility of child witnesses in rape cases and the non-necessity of precise dates in statutory rape cases. The court’s decision further solidifies established jurisprudence on evaluating minor inconsistencies and the corroborative character of medico-legal evidence. The doctrines applied in this case trace their roots back to efforts in the early 2000s to strengthen protections for minors against sexual crimes.
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