In People v. Marmol, the Supreme Court affirmed the conviction of a father for two counts of rape against his minor daughter, emphasizing the inviolability of a child’s safety and the severe consequences for parental breach of trust. The court underscored that a father’s moral ascendancy over his child makes the acts of violence and intimidation even more reprehensible. This decision serves as a stern warning against familial abuse, highlighting that such actions will be met with the full force of the law.

Incestuous Betrayal: The Case of Eduardo Marmol and the Violation of Familial Trust

This case revolves around Eduardo Marmol, who was charged with two counts of rape against his daughter, AAA, aged 12. The incidents allegedly occurred on February 9 and February 22, 2004. AAA testified that on February 9, her father sexually assaulted her, while on February 22, he inserted his finger into her genital area. The RTC found Marmol guilty beyond reasonable doubt, a decision later affirmed with modifications by the Court of Appeals. The primary legal question centers on whether the prosecution presented sufficient evidence to prove Marmol’s guilt, considering the sensitive nature of the charges and the familial relationship involved.

The prosecution presented AAA’s testimony, supported by her mother’s account and medical evidence. AAA recounted the harrowing details of the assaults, describing how her father used his position to intimidate and violate her. BBB, the mother, testified about discovering the second assault and the subsequent events. The Medico-Legal Report, presented by Dr. Bernabe, indicated physical findings consistent with sexual abuse, further corroborating AAA’s statements. The defense, on the other hand, relied on denial and alibi, claiming that Marmol was not present during the alleged incidents. He also suggested that BBB coerced AAA to testify against him. However, the trial court and the appellate court found these defenses unconvincing.

Central to the Court’s decision was the credibility of AAA’s testimony. The Supreme Court reiterated that in rape cases, the victim’s testimony is of utmost importance.

In rape cases, primordial is the credibility of the victim’s testimony because the accused may be convicted solely on said testimony provided it is credible, natural, convincing and consistent with human nature and the normal course of things. (People v. Pascua, 462 Phil. 245, 252 (2003))

The Court found AAA’s testimony to be clear, spontaneous, and consistent. It emphasized that children’s testimonies are given full weight, especially in cases involving such sensitive matters. Moreover, the Court acknowledged the unique dynamic in cases of incestuous rape.

This Court has recognized the moral ascendancy and influence the father has over his child. When a father rapes his daughter, violence and intimidation supplant such moral ascendancy and influence. The rapist father can easily subjugate his daughter’s will, allowing him to coerce the child to do his every bidding. (People v. Pioquinto, 549 Phil. 479, 486-487 (2007))

This consideration underscores the gravity of the offense, as it involves a betrayal of trust and abuse of power within the family.

The medical evidence further supported AAA’s testimony. Dr. Bernabe’s findings of hymenal lacerations and other physical indicators corroborated the accounts of sexual abuse. The Court noted that such medical findings, when consistent with the victim’s testimony, provide a sufficient basis to establish the essential requisites of carnal knowledge.

When the consistent and straightforward testimony of a rape victim is consistent with medical findings, there is sufficient basis to warrant a conclusion that the essential requisites of carnal knowledge have been established. (People v. Perez, 595 Phil. 1232, 1258 (2008))

This convergence of testimonial and medical evidence strengthened the prosecution’s case.

The Court dismissed Marmol’s defense of denial and alibi as weak and self-serving. It reiterated the well-established principle that alibi is the weakest of all defenses, especially when not substantiated by clear and convincing proof. Furthermore, the Court found it inconceivable that AAA would falsely accuse her own father of such a heinous crime unless the accusations were true. Filipino culture places a high value on respect for elders, making it unlikely for a child to fabricate such a damaging accusation against a parent.

It is highly inconceivable for a daughter like AAA to impute against her own father a crime as serious and despicable as incest rape, unless the imputation was the plain truth. (People v. Felan, 656 Phil. 464 Phil. 470 (2011))

The Court also addressed Marmol’s argument regarding inconsistencies in AAA’s gestation period. It clarified that impregnation is not an element of rape, and therefore, any discrepancies in the timeline did not negate the fact that the sexual assaults occurred.

It bears underscoring that impregnation is not an element of rape. (People v. Maglente, 578 Phil. 980, 997 (2008))

The focus remained on whether carnal knowledge occurred against AAA’s will, a fact that the Court found to be convincingly established.

Ultimately, the Supreme Court affirmed the lower courts’ decisions, finding Marmol guilty beyond reasonable doubt. In Criminal Case No. C-70217, for rape through sexual assault, the Court upheld the penalty of eight years and one day of prision mayor, as minimum, to seventeen years and four months of reclusion temporal, as maximum. Additionally, it affirmed the award of P30,000.00 as civil indemnity, P30,000.00 as moral damages, and P30,000.00 as exemplary damages. In Criminal Case No. C-70859, for qualified rape, the Court imposed the penalty of reclusion perpetua and increased the damages to P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages. The Court also ordered that all damages awarded would earn interest at the rate of six percent (6%) per annum from the finality of the judgment until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution provided sufficient evidence to prove beyond reasonable doubt that Eduardo Marmol committed rape against his daughter, AAA. The evidence included AAA’s testimony, medical reports, and corroborating accounts from her mother.
What is the significance of the victim’s testimony in rape cases?	The victim’s testimony is primordial in rape cases. If the testimony is credible, natural, convincing, and consistent with human nature, it can be sufficient to convict the accused, even without additional evidence.
How did the court view the father’s role in the crime?	The court recognized the father’s moral ascendancy and influence over his child. The act of a father raping his daughter is a severe breach of trust and an abuse of power that supplants moral ascendancy with violence and intimidation.
What role did the medical evidence play in the decision?	The medical evidence, specifically the findings of hymenal lacerations and other physical indicators, corroborated AAA’s testimony. This consistency between the victim’s account and the medical findings strengthened the prosecution’s case.
Why was the defense of denial and alibi rejected by the court?	The court rejected the defense of denial and alibi because they were weak and self-serving, lacking clear and convincing proof. Additionally, the court found it implausible that a daughter would falsely accuse her father of such a heinous crime unless the accusations were true.
Is impregnation an element of rape under Philippine law?	No, impregnation is not an element of rape. The focus is on whether carnal knowledge or sexual assault occurred against the victim’s will. Any inconsistencies in the gestation period do not negate the fact of the assault.
What penalties were imposed on the accused in this case?	In Criminal Case No. C-70217, the penalty was eight years and one day of prision mayor, as minimum, to seventeen years and four months of reclusion temporal, as maximum. In Criminal Case No. C-70859, the penalty was reclusion perpetua.
What damages were awarded to the victim in this case?	The damages awarded included civil indemnity, moral damages, and exemplary damages. The specific amounts varied between the two criminal cases, with the total damages significantly increased by the Supreme Court.

This case underscores the Philippine legal system’s commitment to protecting children from sexual abuse and holding perpetrators accountable, especially when the abuse occurs within the family. The decision emphasizes the importance of the victim’s testimony, corroborating evidence, and the gravity of breaching familial trust.

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. Eduardo Marmol y Bauso, Jr., G.R. No. 217379, November 23, 2016