Case Digest (G.R. No. 127126)
Facts:
People of the Philippines v. Rodrigo Calma y Sacdalan, G.R. No. 127126, September 17, 1998, the Supreme Court En Banc, Per Curiam.The accused-appellant, Rodrigo Calma y Sacdalan, was charged before the Regional Trial Court (RTC), 3rd Judicial Region, Malolos, Bulacan, Branch 14, with two counts of rape under Art. 335 of the Revised Penal Code, as amended by Sec. 11 of Republic Act No. 7659, and one count of acts of lasciviousness under Art. 336 of the Revised Penal Code in relation to Sec. 5(b), Art. III of Republic Act No. 7610. The three Informations alleged sexual assaults committed between May 1995 and March 8, 1996, upon his daughters Annalyn (born July 11, 1981), Roselyn (born December 28, 1985) and Irene (born June 29, 1991). The cases were tried jointly on Prosecutor’s motion.
At trial, the three daughters testified in detail about repeated sexual abuses by their father: Annalyn (then 15) and Roselyn (then 11) described forcible vaginal intercourse (including threats with an icepick and ejaculation outside their bodies), while Irene (then 4–5) described digital penetration. The medico-legal officer, Dr. Jesusa Nieves Vergara, examined each child and testified to healed lacerations of the hymen and a non-virgin state compatible with forcible entry. On cross-examination Dr. Vergara conceded that lacerations could sometimes result from a fall on a sharp object but the defense did not establish any such accidents for the children.
The accused denied the charges, asserting that his common-law wife, Myrna Ignacio, coached the children to fabricate allegations to deprive him of property rights; he also admitted past violent acts against his wife. Several defense witnesses—including the accused’s mother and neighbors—testified to the daughters’ continued affection for the accused and suggested improper motives or seduction theories.
On September 25, 1996, the RTC (Presiding Judge Roland B. Jurado) convicted the accused on all three counts. It found the defense theory of fabrication untenable, credited the victims’ testimony and the medico-legal findings, and applied precedents recognizing that a father’s moral ascendancy can substitute for overt force in incest cases. The RTC imposed death sentences for both rape convictions and reclusion temporal (medium) for acts of lasciviousness, awarded indemnity, moral and exemplary damages, and explained its rulings citing numerous Supreme Court precedents. Because of the death sentences the conviction was presented to the Supreme Court on automatic appeal.
On automatic appeal, the accused raised a single error: that the prosecution failed to prove guilt beyond reasonable doubt. The Solicitor General defended the convictions and urged affirmation. The Supreme Court conside...(Subscriber-Only)
Issues:
- Was the prosecution’s evidence sufficient to prove Rodrigo Calma guilty beyond reasonable doubt of two counts of rape and one count of acts of lasciviousness?
- Should the sentences imposed by the trial court — including the death penalty under Republic Act No. 7659...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)