G.R. No. 146790 - People vs. Sitao

The case emanated from an Information charging accused-appellant Romel Vale y Palmaria with the crime of rape of a minor under Article 266-A (1), in relation to Article 266-B of the Revised Penal Code, as amended.
The Information alleged that on October 2, 2013 at around 4:00 PM, at a specified location, Vale by means of force and intimidation committed the act against a nine-year-old girl (referred to as AAA256253) without her consent.
The Information emphasized that the act was committed willfully, unlawfully, and feloniously, causing damage and prejudice to the victim.

According to the prosecution, the victim was on her way to purchase dye for her mother when she was suddenly grabbed by a man. The assailant covered her mouth and dragged her to an isolated, grassy area.
During the assault, the assailant removed the victim’s pants and tied them around her neck, which caused her to lose consciousness.
After regaining consciousness, the victim was found walking home in a half-naked state with her pants still tied around her neck. Her mother, upon noticing signs of distress including red eyes and vaginal bleeding, prompted further investigation.
At the hospital, the victim was medically examined and found to have injuries including an infra-orbital contusion hematoma on her left eye, swelling on her chin, strangulation markings on her neck, and a fresh laceration on her vagina.
The victim positively identified Vale as her attacker when he was brought to the hospital by barangay officials.

Vale denied the allegations against him, asserting that he was at his farm until 10:00 AM and then at home with his wife until 10:00 PM on the day of the incident.
He admitted to leaving his house later in the day to check on some palay drying, but contended that he was not involved in the assault and that the identification by the victim was mistaken.

In its Decision dated May 25, 2018, the Regional Trial Court (RTC) found Vale guilty beyond reasonable doubt for the crime of rape of a minor, sentencing him to reclusion perpetua.
The RTC also ordered Vale to pay civil indemnity, moral damages, and exemplary damages of Php 100,000.00 each, besides the costs of the suit.
The Court of Appeals (CA), in a Decision dated February 24, 2020, affirmed Vale’s conviction with modifications, reducing the amounts for damages to Php 75,000.00 each.
The CA upheld the credibility of the victim’s testimony and medical findings, rejecting Vale’s defenses concerning both the evidentiary and procedural issues.

Whether the Regional Trial Court lacked jurisdiction on the ground that the Information did not carry the signature and prior written authority or approval of the provincial prosecutor, as required under Section 4, Rule 112 of the Rules of Court.
Whether the accused’s failure to timely object to this alleged procedural lapse constitutes a waiver of such jurisdictional challenge.

Whether the evidence presented—including the victim’s positive identification, the circumstantial evidence, and the medical findings—establishes beyond reasonable doubt that Vale committed the crime of rape under Article 266-A (1) in relation to Article 266-B of the RPC.
Whether the fact that the victim was unconscious during part of the incident affects the ability to prove carnal knowledge or the occurrence of sexual intercourse.