Facts:

The case revolves around Renato Baleros, Jr. who filed a petition for partial reconsideration regarding his conviction for light coercion arising from an incident that occurred on December 13, 1991, in Manila. The original charge against Baleros was for attempted rape, as he was accused of forcefully covering the face of the victim, identified as Martina Lourdes T. Albano, with a cloth soaked in a chemical intended to induce dizziness, and attempting to have carnal knowledge of her. The facts presented noted that Baleros did not complete the act of sexual intercourse due to external factors unrelated to his own voluntary withdrawal. The case progressed through the lower courts and culminated in a ruling where the Court of Appeals initially convicted him, which was later reversed by the Supreme Court on February 22, 2006, acquitting him of attempted rape but finding him guilty of light coercion. In his motion for reconsideration, Baleros argued that his conviction for light coerc

...

Facts:

Background of the Case

• Renato Baleros, Jr. filed a Motion for Partial Reconsideration challenging the Court’s Decision of February 22, 2006.
• The challenged decision acquitted him of the crime of attempted rape but convicted him of light coercion by way of unjust vexation.
• He was sentenced to 30 days of arresto menor, fined P200.00 (with accessory penalties), and ordered to pay court costs.

Allegations in the Indicting Information

• The Information alleged that on or about 1:50 in the morning (or sometime thereafter) on December 13, 1991, in Manila, within the jurisdiction of the court, the accused committed an act intended to facilitate rape.
• Specifically, it was stated that the accused forced his way into the commission of rape by covering the face of the victim, Martina Lourdes T. Albano (referred to as Malou), with a cloth soaked in a chemical substance with dizzying effects.
• The accused’s act, albeit an incomplete execution of rape due to some cause or accident beyond his control, was alleged to have been performed against the will and consent of the victim.

Presentation of Evidence and Victim’s Reaction

• The complaint emphasized that the Information contained all necessary facts and ingredients to inform the accused of the precise nature of the charge against him, fulfilling his constitutional right to be adequately informed.
• Testimony and evidentiary submissions indicated that following the incident, the victim was visibly disturbed—she cried while recounting the events to her classmates—and subsequently, she filed a case for attempted rape, thereby evidencing the alleged mental and emotional distress.

Comparison with Prior Jurisprudence (People v. Contreras)

• The petitioner argued that the conviction for light coercion (through unjust vexation) was improperly based on the same Information used in an attempted rape charge and compared it to People v. Contreras.
• In People v. Contreras, the Court had held that the elements of unjust vexation did not form part of the crime of rape, as the Information in that case did not adequately allege the necessary elements for such a conviction.
• The petitioner contended that his conviction should be similarly invalidated due to the absence of alleged annoyance, irritation, torment, distress, and disturbance in the Information.

Distinctions in the Present Case

• Contrary to the Controversial approach in Contreras, the Information in the instant case undeniably alleged that the accused’s act—covering the victim’s face with a chemical-soaked cloth—caused annoyance, irritation, torment, distress, or disturbance.
• The legal sufficiency of the Information was upheld, as the act itself, even absent explicit allegations of malice, compulsion or restraint, was enough to constitute unjust vexation under the law.

Issue:

Sufficiency of the Charging Document

• Whether the Information adequately and clearly apprised the petitioner of the nature and cause of the accusation in strict compliance with his constitutional right to be informed of the charges.

Nature of the Act Committed

• Whether the act of covering the victim’s face with a chemical-soaked cloth that produced dizzying effects qualifies as unjust vexation (a form of light coercion) under the Revised Penal Code.

Relevance of Prior Jurisprudence

• Whether the ruling in People v. Contreras, which involved similar allegations in a different context (statutory rape), is applicable and controlling in ascertaining the sufficiency of the elements for unjust vexation in this case.

Elemental Requirements for Unjust Vexation

• Whether the Information need expressly allege that the act caused annoyance, irritation, torment, distress, or disturbance, or if the mere showing of these effects through the victim’s reaction is sufficient for conviction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)