The Supreme Court affirmed the conviction of Marcelo Caliso for twice raping his daughter, emphasizing that the victim’s credible testimony alone is sufficient for conviction in rape cases, particularly when the crime is incestuous. The Court underscored that while the exact date of the offense is not critical, the act of carnal knowledge under circumstances of force or intimidation is paramount. It also clarified the penalties and damages applicable under the Revised Penal Code and Republic Act No. 7659, adjusting the initial decision to align with legal requirements for proving qualified rape.

When a Father’s Betrayal Meets Justice: Examining the Proof of Rape in Incest Cases

The case of People vs. Marcelo Caliso revolves around two separate informations filed against Marcelo Caliso for the rape of his daughter, AAA. The incidents allegedly occurred in July 1993 and February 1994. The central legal question before the Supreme Court was whether the prosecution successfully proved Caliso’s guilt beyond a reasonable doubt, given the inconsistencies and delays in AAA’s testimony, and whether the imposed penalties were appropriate under the law.

At trial, AAA testified that her father committed these heinous acts by using force and intimidation, including threats with a bolo and garrote, which instilled fear and prevented her from resisting or reporting the incidents immediately. The prosecution presented medical evidence confirming healed lacerations of AAA’s hymen, which supported her claims of sexual assault. This evidence was crucial in corroborating her testimony.

The defense, led by Caliso, presented a narrative aimed at discrediting AAA’s character and motives. Caliso portrayed AAA as a liar with loose morals, recounting incidents where she allegedly acted violently and disobeyed parental rules. He further claimed that AAA fabricated the rape charges because he refused to sell their family property. These claims were directly contradicted by Caliso’s wife and AAA’s mother, Francisca, who testified that Caliso was often abusive and did not own the property he claimed AAA wanted to sell.

In its analysis, the Supreme Court highlighted that rape, by its nature, often occurs in private settings with only the victim and perpetrator present. The Court reaffirmed the principle that the testimony of a rape victim is sufficient to warrant a conviction if found credible.

“Thus, the lone testimony of a rape victim, by itself, is sufficient to warrant a judgment of conviction if found to be credible.”

The Court noted that the inconsistencies regarding the exact date of the first rape were minor and did not detract from the overall credibility of AAA’s testimony.

Addressing the delay in reporting the incidents, the Court acknowledged that a victim’s silence is not always indicative of a false accusation. AAA testified that Caliso threatened to kill her and her siblings if she reported the assaults, which explained her delayed disclosure. The Court recognized the element of moral ascendancy a parent holds over a child, especially in cases of incest, which can induce fear and silence.

Regarding the claim that AAA had an ill motive in accusing her father, the Court found Caliso’s argument baseless. His wife testified that he did not own the property he claimed AAA wanted to sell, undermining his entire defense. The Court emphasized that it is highly improbable for a young girl to fabricate such a grave accusation against her own father, especially considering the personal humiliation and public scrutiny involved in a rape trial.

The Court also dismissed Caliso’s argument that the prosecution failed to prove carnal knowledge in the first rape incident. AAA’s descriptions of her father’s actions, coupled with the medical evidence of healed lacerations, sufficiently established that penetration occurred.

“Indeed, when a woman declares that she has been raped, she says in effect all that is necessary to mean that she has been raped, and where her testimony passes the test of credibility the accused can be convicted on the basis thereof.”

With respect to the penalty imposed for the rape committed on February 15, 1994, the trial court initially sentenced Caliso to death, citing Republic Act No. 7659, which provides for the death penalty if the victim is under eighteen years of age and the offender is a parent. However, the Supreme Court modified this penalty, noting that the information filed against Caliso did not specify AAA’s age at the time of the crime. The Court emphasized that every element of the crime must be properly alleged in the information to ensure the accused is fully informed of the charges against them. Therefore, the death penalty was reduced to reclusion perpetua.

Finally, the Court addressed the issue of damages. While the trial court awarded moral and exemplary damages, it omitted civil indemnity. The Supreme Court clarified that civil indemnity is mandatory upon finding a defendant guilty of rape. Consequently, the Court ordered Caliso to pay AAA ₱50,000.00 as civil indemnity for each count of rape, in addition to the moral and exemplary damages already awarded.

FAQs

What was the key issue in this case?	The central issue was whether the prosecution presented sufficient evidence to prove Marcelo Caliso’s guilt beyond a reasonable doubt for the rape of his daughter, AAA, and whether the penalties imposed were appropriate.
Is the victim’s testimony alone sufficient for a rape conviction?	Yes, the Supreme Court reiterated that the lone testimony of a rape victim is sufficient for conviction if the testimony is credible and consistent. This is especially true in cases where the crime occurs in private and without other witnesses.
Why did the Court reduce the death penalty to reclusion perpetua in one of the rape cases?	The death penalty was initially imposed because the victim was under 18 and the perpetrator was her father, a qualifying circumstance under Republic Act No. 7659. However, the Supreme Court reduced the penalty because the information filed did not specify the victim’s age, which is a necessary element for imposing the death penalty.
What is civil indemnity in the context of a rape case?	Civil indemnity is a mandatory monetary compensation awarded to the victim of rape, distinct from moral and exemplary damages. It is automatically granted upon conviction to compensate for the inherent harm caused by the crime.
How did the Court address the delay in reporting the rape incidents?	The Court acknowledged that delays in reporting do not automatically discredit a victim’s testimony, especially when the victim fears the perpetrator. AAA’s fear of her father, who threatened her and her siblings, explained her delay in reporting the incidents.
What role did medical evidence play in the case?	Medical evidence, specifically the healed lacerations of AAA’s hymen, corroborated her testimony and supported the conclusion that sexual assault occurred. This evidence helped establish the element of carnal knowledge.
Can a victim’s testimony be considered credible if there are minor inconsistencies?	Yes, minor inconsistencies, such as discrepancies in dates, do not necessarily discredit a victim’s testimony. The Court recognized that traumatic experiences can affect memory, and the essential element is the consistent account of the assault.
What should an information include to impose the death penalty in a rape case involving a minor and a parent?	The information must specifically allege both the minority of the victim and the familial relationship between the victim and the offender. Failure to include these elements prevents the imposition of the death penalty.

The Supreme Court’s decision in People vs. Marcelo Caliso reaffirms the importance of protecting vulnerable individuals from sexual abuse, especially within familial settings. The ruling serves as a reminder of the weight given to the victim’s testimony in rape cases and the necessity of adhering to procedural requirements when imposing severe penalties.

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. Marcelo Caliso, G.R. Nos. 131475-76, October 14, 2002