Facts:

The case involves Isidro Flores y Lagua, the accused-appellant, who was found guilty of two counts of rape against his adoptive daughter, referred to as AAA. The events leading to the case occurred in Makati City, Philippines, with the alleged crimes taking place between February 1999 and October 2002. AAA was only 11 years old at the time of the first incident and 14 years old at the time of the last incident. The Regional Trial Court (RTC) of Makati City, Branch 140, initially handled the case, where 181 Informations were filed against the appellant, detailing the rapes committed against AAA. During the pre-trial, it was established that AAA was 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 incidents of sexual abuse.

AAA recounted that the first incident occurred when she was sleeping, and Isidro touched her thighs and later threatened her with a knife b...

Facts:

Background and Charges

• Appellant Isidro Flores y Lagua was charged with 181 counts of rape in the Regional Trial Court (RTC) of Makati City. The charges stemmed from allegations that he raped his adoptive daughter, AAA, multiple times from February 1999 to October 2002.
• The Informations alleged that appellant, as the adoptive father of AAA, used force and intimidation to commit the rapes while AAA was below 15 years old.

Stipulated Facts

• During pre-trial, the parties stipulated that:
  1. AAA was below 15 years old at the time of the incidents.
  2. Appellant was AAA’s guardian.
  3. AAA had been under the care and custody of appellant and his wife since she was one and a half years old.

Prosecution’s Version

• AAA testified that the first incident occurred in February 1999 when appellant touched her thighs while she was sleeping. Appellant threatened her not to tell anyone.
• Two weeks later, appellant raped AAA at knifepoint, inserting his penis into her vagina. AAA resisted but was overpowered.
• Appellant continued to rape AAA approximately three times a week until October 15, 2002.
• On October 16, 2002, AAA confided in her friend, Marvin, about the rapes. Marvin encouraged her to report the incidents.
• AAA and Marvin sought help from barangay officials, leading to appellant’s arrest.

Medical Evidence

• A medico-legal examination confirmed that AAA was in a "non-virgin state" with healed lacerations on her hymen, consistent with sexual intercourse.

Defense’s Version

• Appellant denied the allegations, claiming AAA had a tendency to fabricate stories. He admitted to being strict with AAA but denied any sexual abuse.

Trial Court Decision

• The RTC found appellant guilty of all 181 counts of rape and sentenced him to death for each count, citing AAA’s credible testimony and the qualifying circumstances of minority and relationship.

Court of Appeals Decision

• The Court of Appeals affirmed appellant’s guilt but only for two counts of rape (the first and last incidents). The court acquitted him of the other 179 counts due to insufficient evidence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of the Victim’s Testimony:

   • The testimony of AAA was deemed credible, consistent, and corroborated by medical evidence. The Court emphasized that when a minor alleges rape, her testimony is given weight unless proven otherwise.

2. Qualifying Circumstances:

   • The Court ruled that the prosecution failed to prove that appellant was AAA’s legal guardian. A guardian must have a legal relationship with the ward, such as through a judicial appointment or adoption. Mere custody or de facto guardianship is insufficient to qualify for the higher penalty.

3. Sufficiency of Evidence:

   • The Court agreed with the Court of Appeals that only two counts of rape were proven beyond reasonable doubt. The other counts lacked specific details and were based on general allegations.

4. Penalties and Damages:

   • Since the qualifying circumstances were not proven, appellant could only be convicted of simple rape, punishable by reclusion perpetua.
   • The awards of civil indemnity and moral damages were adjusted in line with prevailing jurisprudence, while exemplary damages were increased due to the use of a deadly weapon during the commission of the crime.

Conclusion:

• The Supreme Court affirmed appellant’s conviction for two counts of simple rape but acquitted him of the other charges. The penalties and damages were modified to reflect the absence of qualifying circumstances and the use of a deadly weapon.