Title
People vs. Flores y Lagua
Case
G.R. No. 188315
Decision Date
Aug 25, 2010
Isidro Flores was convicted of simple rape for assaulting a minor, with differing charges for incidents at ages 11 and 13, and the court denied guardian status while awarding damages to the victim.
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Case Digest (G.R. No. 188315)

Facts:

  • Isidro Flores y Lagua was accused of raping his adoptive daughter, referred to as AAA.
  • The incidents occurred in Makati City, Philippines, between February 1999 and October 2002.
  • AAA was 11 years old during the first incident and 14 years old during the last.
  • The Regional Trial Court (RTC) of Makati City, Branch 140, handled the case, with 181 Informations filed against Isidro.
  • AAA had been under the care of Isidro and his wife, BBB, since she was one and a half years old.
  • The prosecution presented five witnesses, including AAA, who testified about the sexual abuse.
  • AAA described the first incident involving Isidro touching her thighs and threatening her with a knife before raping her.
  • The abuse reportedly occurred approximately three times a week until October 15, 2002.
  • After confiding in a friend, AAA reported the incidents, leading to Isidro's arrest.
  • The RTC found Isidro guilty of 181 counts of rape and sentenced him to death for each count.
  • The Court of Appeals affirmed the conviction but modified it to two counts of rape, sentencing Isidro to reclusion perpetua.

Issue:

  • (Unlock)

Ruling:

  • The Court of Appeals affirmed Isidro Flores y Lagua's conviction for two counts of rape, finding sufficient evidence.
  • The Court erred in considering the relationship as a qualifying circumstance for a higher penalty, as Isidro was not a legally recognized guardian.
  • ...(Unlock)

Ratio:

  • The Court upheld the conviction based on the credibility of AAA's testimony, which was straightforward and consistent.
  • The prosecution's evidence, including a medico-legal report confirming lacerations consistent with sexual abuse, supported the findings of guilt beyond reasonable doubt for the two coun...continue reading

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