The Supreme Court, in People v. Acala, addressed the conviction of Reynaldo Acala for three counts of incestuous rape against his daughter. While upholding the conviction based on the daughter’s credible testimony and corroborating evidence, the Court modified the penalty. The original sentence of death for each count was reduced to reclusion perpetua because the information filed in court did not specifically allege the victim’s age at the time of the commission of the crime, precluding the application of the death penalty under Republic Act No. 7659, which requires that the victim be under eighteen years of age and the offender is a parent.

When a Father’s Betrayal Meets the Scales of Justice

The case of People v. Acala presents a harrowing account of a father, Reynaldo Acala, accused and later convicted of the repeated incestuous rape of his daughter, Fe Acala. The initial complaints detailed three specific instances of rape occurring on December 26, 1995, and January 12 and 19, 1996. The Regional Trial Court found Reynaldo guilty on all three counts, sentencing him to death for each, along with damages to be paid to the victim. This decision was then elevated to the Supreme Court for automatic review, given the gravity of the penalty imposed.

The defense sought to overturn the conviction, primarily arguing that the victim’s initial sworn statement failed to mention the incidents of December 26, 1995, and January 12, 1996, casting doubt on her credibility. They also pointed to the medico-legal findings of no fresh lacerations or spermatozoa as evidence against the claim of rape on January 19, 1996. Furthermore, the defense suggested that the victim harbored resentment towards her father due to his behavior as a gambler and for allegedly mistreating her mother. The accused also highlighted the lack of witnesses to the alleged rapes as a point of contention.

However, the Supreme Court affirmed the trial court’s findings, emphasizing the victim’s credible and consistent testimony. The Court addressed the defense’s arguments, explaining that the victim’s initial confusion and fear were common responses to such traumatic experiences, as supported by expert testimony from a family counselor. Moreover, the healed lacerations found during the medical examination were consistent with repeated sexual abuse, and the absence of spermatozoa did not negate the commission of rape. Ultimately, the Court found the victim’s testimony to be spontaneous, convincing, and unshaken by cross-examination. The Court gave more weight on her testimony given in court over the sworn statement.

The Court also pointed out the weakness of the accused’s defense of alibi and denial. Alibi, the defense that the accused was elsewhere when the crime was committed, requires concrete evidence demonstrating the impossibility of the accused being at the scene of the crime. In this case, the accused failed to provide such evidence. Similarly, the accused’s denial was unsubstantiated and carried less weight than the positive affirmations of the prosecution’s witnesses.

A critical point of contention was the imposition of the death penalty. Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, stipulates that the death penalty may be imposed in rape cases when “the victim is under eighteen (18) years of age and the offender is a parent… of the victim.” However, the Supreme Court clarified that for this provision to apply, the minority of the victim and the familial relationship between the offender and the victim must be explicitly alleged in the criminal complaint. In this case, while the familial relationship was established, the victim’s age was not specifically stated in the complaints, thus precluding the imposition of the death penalty. Instead, the Court applied the second paragraph of Article 335, sentencing the accused to reclusion perpetua for each count of rape.

With respect to damages, the trial court awarded P50,000.00 as moral damages and P25,000.00 as exemplary damages for all three counts of rape. The Supreme Court modified this, awarding P50,000.00 as moral damages for each count, aligning with prevailing jurisprudence. Additionally, an indemnity of P50,000.00 for each count was granted, distinct from moral damages, as it is automatically awarded in rape cases. However, the award for exemplary damages was deleted due to the absence of sufficient legal basis.

FAQs

What was the key issue in this case?	The key issue was whether the accused, Reynaldo Acala, was guilty beyond reasonable doubt of three counts of incestuous rape and whether the death penalty was properly imposed given the circumstances. The imposition of the death penalty hinged on whether the victim’s age was properly alleged in the complaints.
Why was the death penalty not upheld by the Supreme Court?	The death penalty was not upheld because the complaints did not explicitly state the victim’s age at the time the crimes were committed. The Supreme Court clarified that for the death penalty to be imposed under Article 335 of the Revised Penal Code, as amended, the minority of the victim must be alleged in the complaints.
What is reclusion perpetua?	Reclusion perpetua is a term for life imprisonment under Philippine law. It is a penalty imposed for serious crimes, and in this case, it replaced the death penalty due to the procedural lapse in the complaints.
What is the significance of the healed lacerations found during the medical examination?	The healed lacerations were considered significant as they supported the claim of repeated sexual abuse. The absence of fresh lacerations did not negate the rape, as the victim was no longer a virgin at the time of the examination, indicating previous instances of sexual contact.
Why did the Supreme Court give more weight to the victim’s testimony than her initial sworn statement?	The Supreme Court gave more weight to the victim’s testimony in court because sworn statements taken ex parte are often incomplete due to suggestion or lack of inquiries. Testimony given in court allows for a more thorough examination and cross-examination, providing a fuller account of the events.
What are moral damages and indemnity in this case?	Moral damages are awarded to compensate the victim for the emotional distress and suffering caused by the rape. Indemnity is a separate monetary award that is automatically granted in rape cases to acknowledge the violation and harm inflicted upon the victim.
Why was the award of exemplary damages deleted?	The award of exemplary damages was deleted because there was no sufficient legal basis to justify it. Exemplary damages are awarded as a form of punishment or to set an example, but the Court found that the circumstances of the case did not warrant such an award.
What role did parental authority play in this case?	The court noted that the father’s moral ascendancy and influence over his daughter effectively replaced violence or intimidation. This influence stemmed from his parental authority, which should have been used for protection but was instead perverted to commit the crime.

The Supreme Court’s decision in People v. Acala underscores the importance of due process and proper pleading in criminal cases, especially those involving severe penalties. While the conviction was affirmed based on the strength of the evidence and the victim’s credible testimony, the modification of the penalty reflects a commitment to upholding procedural rights and ensuring that penalties are imposed in strict accordance with the law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, vs. Reynaldo Acala, G.R. Nos. 127023-25, May 19, 1999