People v. Cutamora
REITERATIONFacts
The Antecedents: Accused-brothers Roselindo and Allan Cutamora were charged with three counts of rape each, allegedly committed against their nieces Virginia Cutamora (ages 7-11), Gina Cutamora (ages 6-8), and Beatriz Tampos y Cutamora (ages 10-13). The alleged rapes occurred within the house of their grandparents, Uldarico and Cedra Cutamora, in Kalaitan, Bayugan, Agusan del Sur, between the years 1989 and 1993. The victims testified that Roselindo and Allan repeatedly sexually assaulted them, with threats of harm or death. The accused denied the charges, claiming they were at their farm during the alleged incidents. Procedural History: The Regional Trial Court (RTC) found both accused guilty beyond reasonable doubt of three counts of rape each and sentenced them to three separate penalties of reclusion perpetua, with indemnification and damages. The accused appealed the decision. The Petition: The accused-appellants argued that the informations were insufficient for failing to state the exact dates of the alleged offenses, thus violating their right to be informed of the nature and cause of the accusation. They also contended that their guilt was not proven beyond reasonable doubt.
Issue(s)
Whether the informations were sufficient despite not stating the exact dates of the alleged commission of the crimes. Whether the guilt of the accused-appellants was proven beyond reasonable doubt.
Ruling
The Supreme Court affirmed the conviction of the accused-appellants, finding them guilty beyond reasonable doubt of three counts of rape each. Each accused was sentenced to three separate penalties of reclusion perpetua and ordered to pay civil indemnity and moral damages to each victim.
Ratio Decidendi
On the sufficiency of the informations: The Court held that the informations were sufficient. Citing Section 6, Rule 110 of the Rules of Court, the Court stated that an information is sufficient if it states the name of the accused, the designation of the offense, the acts or omissions constituting the offense, the name of the offended party, the approximate time of the commission of the offense, and the place where it was committed. The informations in this case named the accused, designated the crime of rape, described the acts constituting the offense, named the offended parties, stated the approximate time as "sometime in the year 1990 up to 1993," and specified the place. The Court emphasized that the approximate time is sufficient to inform the accused of the charges and enable them to prepare their defense, especially since the victims were minors and continuously endured the assaults over a period of years. Furthermore, the Court noted that the precise time of the commission of the crime is not an essential element in the crime of rape and need not be accurately stated. The Court also pointed out that any objection to the sufficiency of the information should have been raised before arraignment; by failing to do so, the accused-appellants waived their right to question it. On the guilt of the accused-appellants: The Court found no reason to disturb the trial court's assessment of the witnesses' credibility. The testimonies of the minor victims, despite the traumatic nature of their experiences, were found to be credible and substantially corroborated by medical examinations. The Court reiterated that the testimonies of child-victims are given full weight and credit, as youth and immaturity are generally badges of truth and sincerity. The Court also found the accused-appellants' denial and alibi to be weak and inconsistent, particularly their conflicting statements regarding the distance of their farm from their residence. Given the positive testimonies of the victims and the lack of ill-motive on their part to falsely accuse their own kin, the Court concluded that the prosecution had proven the guilt of the accused-appellants beyond reasonable doubt.
Main Doctrine
The approximate time of the commission of an offense, as stated in an information, need not be exact, especially in cases involving minor victims of rape, as long as it enables the accused to prepare their defense and does not substantially prejudice them. Furthermore, objections to the sufficiency of an information must be raised before arraignment; otherwise, they are deemed waived.