G.R. No. 186460 - People vs. Cinco y Soyosa

Gualberto Cinco y Soyosa was accused of two counts of simple rape and one count of acts of lasciviousness against a minor, AAA, who was 14 years old at the time of the incidents.
The charges stemmed from events occurring in November 1998, with the first information filed for acts of lasciviousness on November 30, 1998, and two separate informations for rape filed on August 18, 1999.
The allegations included that the accused used force and intimidation to undress AAA and have carnal knowledge of her against her will.

The prosecution's case relied on the testimonies of AAA and Dr. Marietta Castillo, who conducted a medical examination of AAA.
AAA testified that on November 1, 1998, the accused threatened her with a knife, tied her hands, and raped her. A similar incident occurred later in November.
Medical examinations revealed injuries consistent with sexual assault, including a lacerated hymen.

The defense presented testimonies from the accused and two witnesses, asserting that the accused was selling ice cream during the times of the alleged incidents.
The accused claimed that AAA had a motive to fabricate the charges due to previous thefts from him.

The Regional Trial Court (RTC) convicted the accused of two counts of rape and acquitted him of acts of lasciviousness due to insufficient evidence.
The RTC sentenced the accused to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to AAA.

The accused appealed the RTC's decision, arguing that the informations were insufficient because they did not specify the exact dates of the alleged rapes.
The Court of Appeals affirmed the RTC's decision, finding that the informations were sufficient and that the exact dates were not material to the charges.

An information must include the name of the accused, the designation of the offense, the acts constituting the offense, the name of the offended party, the approximate date of the offense, and the place of commission.
The law allows for flexibility regarding the exact date of the offense, particularly in rape cases, where the gravamen is the act of carnal knowledge rather than the specific timing.

The Court ruled that the informations were valid, as they provided sufficient detail to inform the accused of the charges against him.
The Court emphasized that the precise date of the commission of rape is not an essential element of the crime, and the allegations were adequate for the purpose of prosecution.