FACTS:

Meliton Jalbuena, the accused-appellant, was charged with raping his minor daughter, AAA. According to the prosecution's evidence, on the morning of August 19, 1996, while AAA's mother was away, the accused-appellant entered AAA's bed and forcibly had sexual intercourse with her. He cautioned her not to report the incident or else something bad would happen to her. This rape occurred three times, and the last incident was even witnessed by AAA's uncle. Over time, AAA found the courage to confide in her classmates and school authorities about the rape. She underwent a medical examination conducted by Dr. Marilyn Salumbides, who found that AAA's hymen was still intact. The accused-appellant denied the allegations, arguing that his usual work schedule made it impossible for him to commit the rape. His wife supported his alibi defense.

The trial court found AAA's testimony credible and convicted the accused-appellant of statutory rape, imposing the death penalty as punishment. The case was elevated to the appellate court and eventually reached the Supreme Court. Among the issues raised by the accused-appellant was the alleged failure of the information to specify the exact date of the rape.

ISSUES:

1. Whether or not the information is sufficient to support a judgment of conviction for failure to state the precise date of the commission of the rape.

RULING:

1. The Supreme Court ruled that the information is sufficient to support a judgment of conviction despite the failure to state the precise date of the commission of the rape. The Court cited Section 11, Rule 110 of the Rules of Court which states that it is not necessary to state the precise time of the commission of the offense, except when the time is a material ingredient of the offense. In the case of rape, the date is not an essential element of the offense. Therefore, the lack of a specific date in the information does not violate the accused's right to be informed of the nature and cause of the accusation against him.

PRINCIPLES:

• In rape cases, it is not necessary to state the precise time of the commission of the offense in the information, unless the time is a material ingredient of the offense. (Section 11, Rule 110 of the Rules of Court)