Case Digest: PEOPLE OF THE PHILIPPINES v. MELITON JALBUENA y TADIOSA, 526 SCRA 500 (2007)

PEOPLE OF THE PHILIPPINES v. MELITON JALBUENA y TADIOSA, 526 SCRA 500 (2007)

If the testimony of the victim passes the test of credibility, the accused may be convicted solely on that basis. Meliton Jalbuena y Tadiosa was charged and convicted with rape of his daughter, AAA, who is a minor. On appeal, Jalbuena contends that the testimony of his daughter was inconsistent. He also questions as fatally defective the information for failure to allege the date and time of the commission of the offense charged, thus violating his constitutionally protected right to be informed of the nature and cause of the accusation against him and depriving him of the opportunity to prepare for his defense. Furthermore, Jalbuena contended that the prosecution failed to present testimony from the victims uncle who saw him on top of AAA. On appeal, the Court of Appeals affirmed the conviction.

ISSUE:

Whether or not Jalbuena was convicted on evidence beyond reasonable doubt

HELD:

In rape cases, the credibility of the victim is almost always the single most important issue. If the testimony of the victim passes the test of credibility, the accused may be convicted solely on that basis. The credibility of the testimony of the offended party is put to a stringent test in order that it could be said as credible to sustain a conviction. The Court finds AAA‘s testimony to have passed said test. Her testimony given in open court is clear, consistent, direct and without any hesitation when confronted by the presence of her own abuser. It is noted that AAA had to tell her story several times – to her two classmates, to the teacher, the principal, the police, the doctor, the Municipal Trial Court Judge who conducted the preliminary investigation, to the prosecutor, to the social worker and to this Court, in the presence of the public and her father. Jalbuena never objected to the presentation of evidence by the prosecution to prove that the offenses were committed ―on or about sometime 1987, prior and subsequent thereto. He cannot now pretend that in view of the vagueness of the allegation in the Information as to when the crimes were committed, as it was shown to the contrary that he participated in the trial and was even able to give an alibi in his defense.