Facts:

• Marcelo Caliso was convicted by the Regional Trial Court for two counts of rape against his daughter, Joyce C. Caliso.
• The first rape was committed in July 1993, and the second rape was committed on February 15, 1994.
• Appellant was sentenced to reclusion perpetua for the first rape and death penalty for the second rape.
• Appellant appealed the conviction, questioning the credibility of the complainant and the delay in reporting the incidents.

Issue:

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Ruling:

• The Supreme Court affirmed the decision of the trial court, finding appellant guilty of the two counts of rape.
• The Court reduced the death penalty imposed to reclusion pe...(Unlock)

Ratio:

• The fact that the complainant appeared unsure of the exact date of the first rape does not discredit her whole testimony. It is not unusual for a young girl who experienced incestuous rape to forget the exact date of the traumatic incident.
• The precise date of the rape is not an essential element of the crime. The gravamen of the offense is carnal knowledge under the circumstances enumerated in the law.
• The victim's long silence and inaction are not always indications of false accusation. In this case, the victim testified that the appellant threatened to kill her and her siblings if she reported the sexual assaults. The victim's delay in reporting the rape is understandable and does not affect her credibility.
• The defense's argument that the victim filed the rape charges due to appellant's refusal to sell their house and lot is baseless and ridiculous. The victim's motive for accusing her own father of rape cannot be attributed to such a trivial reason.
• The victim's testimony, supported by medical findings, is sufficient to prov...continue reading