G.R. No. 138235 . May 10, 2001.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO PALERO y DELOS SANTOS, accused-appellant.

FACTS

The case involves the rape of Gigi Palero by her father, accused-appellant Roberto Palero. The incidents occurred in their home in Barangay Cagliliog, Tinambac, Camarines Sur, and at a remote copra kiln. In May 1996, while Gigi’s mother was in Manila, Roberto, taking advantage of the night and the absence of others, removed Gigi’s underwear, pinned her down, and forcibly had carnal knowledge of her. This initial assault was followed by multiple other instances of rape, including at the family’s coconut farm, where Roberto would isolate Gigi. The victim endured the abuse in silence due to threats from her father until she eventually confided in her elder half-sister, Gemma. Her mother, Estrella Palero, disbelieved the allegations and even supported the accused during the trial.
The medical examination confirmed findings consistent with sexual intercourse. The Information filed charged Roberto Palero with one count of rape committed in May 1996, although the victim’s testimony detailed multiple incidents from 1995 to 1996. The Regional Trial Court found him guilty and imposed the death penalty. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the guilt of accused-appellant Roberto Palero for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the victim, Gigi Palero, to be credible, straightforward, and consistent. The defense of denial and alibi proffered by the accused was weak and uncorroborated. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The fact that the rape was committed by the victim’s father constituted the qualifying circumstance of relationship, warranting the imposition of the death penalty under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659 .
The Court modified the civil liabilities, increasing the civil indemnity to P75,000.00 and awarding moral damages of P50,000.00, in accordance with prevailing jurisprudence. The decision was affirmed with these modifications. Four Justices maintained their dissent regarding the constitutionality of the death penalty but submitted to the majority ruling. The records were ordered transmitted to the Office of the President for possible exercise of the pardoning power.