G.R. No. 241850 - Labay vs. People

The appellant, Isidro Flores y Lagua, was charged with 181 counts of rape before the Regional Trial Court (RTC) of Makati, Branch 140.
The complainant, AAA, was appellant's adopted daughter and was below 15 years of age during the incidents.
The charges spanned from February 1999 to 15 October 2002, covering multiple alleged rape incidents.

AAA was adopted and had lived with appellant and his wife, BBB, since infancy.
BBB was employed as a restaurant supervisor working late hours, which left AAA in appellant's care often.
Appellant had previously worked abroad for six years and returned to live with AAA and BBB in 1997.

AAA testified that appellant sexually abused her multiple times approximately three times a week from February 1999 until October 2002.
The acts included unwelcome touching, threats with a knife, and forced sexual intercourse.
AAA disclosed the abuse to her friend, Marvin Suello, in October 2002, after which a complaint was filed.
Police and barangay officials apprehended the appellant shortly after.
Medico-legal examination revealed healed lacerations on AAA’s hymen, confirming physical evidence of sexual abuse.
Witness testimonies corroborated AAA’s account, establishing force and intimidation elements.

The appellant admitted acting as a strict parent but denied all rape accusations.
He alleged AAA was prone to fabricating stories and even stole money from her grandmother.
He explained her absence after school in October 2002 as going out for a school project.

The RTC found appellant guilty beyond reasonable doubt of all 181 counts of rape.
It sentenced appellant to death per count and ordered separate awards for moral and exemplary damages.
The court gave weight to the victim’s consistent and credible testimony, corroborated by medical and other evidences.

The Court of Appeals (CA) dismissed appellant’s motion for failure to file brief initially, reviving the case on automatic review due to the penalty of death involved.
The CA affirmed guilt, but limited conviction to only two counts of rape (the first and last incidents), acquitting appellant of the remaining 179 counts due to insufficient specific evidence for each separate offense.
The CA modified the sentence from death to reclusion perpetua pursuant to Republic Act No. 9346 and awarded damages to the victim.

Appellant challenged the sufficiency of victim’s testimony and the court’s appreciation of the “guardian” qualifying circumstance for penalty.
He argued that as an “adopting father” without a judicial decree of adoption, he did not qualify as guardian under the law.
The Office of the Solicitor General (OSG) supported the conviction based on consistent testimony and medico-legal evidence, moving for modification of the penalty from death to reclusion perpetua.

Whether the Court of Appeals erred in convicting appellant for two counts of rape based on the victim's testimony and medico-legal evidence.
Whether the Court of Appeals correctly applied the qualifying circumstance of "guardian" in imposing the death penalty or reclusion perpetua.
Whether the evidentiary requirements for multiple counts of rape were properly established for all alleged incidents.
Proper penalty and damages to be imposed on appellant considering current laws and jurisprudence.