Title
People vs. Lantano
Case
G.R. No. 176734
Decision Date
Jan 28, 2008
Jacinto Lantano was convicted of raping his 14-year-old daughter, with the court upholding the conviction, citing justified reporting delays due to fear and threats, and affirming the trial court’s credibility assessment while modifying the penalty to reclusion perpetua.
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Case Digest (G.R. No. 176734)

Facts:

  • Jacinto Lantano was convicted of raping his fourteen-year-old daughter, AAA, in Tagudin, Ilocos Sur, Philippines, between April 1998 and January 1999.
  • The Regional Trial Court found him guilty of violating Articles 266-A and 266-B of the Revised Penal Code, as amended by Republic Act No. 8353, in relation to Republic Acts Nos. 7610 and 7659.
  • The Information stated that Lantano had carnal knowledge of AAA through force and intimidation, aggravated by their familial relationship.
  • AAA testified that on April 11, 1998, while lying in bed with her younger sibling, Lantano approached her, kissed her, and made a disturbing remark about her mother.
  • He threatened her with a knife, forcibly removed her clothing, and raped her, warning her not to tell anyone afterward.
  • AAA initially remained silent due to fear, later revealing the incident to her mother through letters and eventually to her grandfather, leading to a police report and medical examination confirming signs of rape.
  • Lantano's defense was an alibi, claiming he was fishing with relatives during the incident, but the trial court found this unconvincing and sentenced him to death.
  • The Court of Appeals modified the sentence to reclusion perpetua, which Lantano appealed.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the delay in reporting the rape was justified and did not undermine AAA's credibility.
  • The Court upheld the trial court's dismissal of Lantano's alibi, finding it unconvincing.
  • The eviden...(Unlock)

Ratio:

  • The Supreme Court emphasized that delays in reporting rape, especially in incest cases, often stem from fear and intimidation by the perpetrator.
  • Victims may hesitate to report due to psychological terror, particularly when the aggressor is a family member.
  • AAA's fear was heightened by Lantano's threats and the presence of a knife during the assault, which silenced her.
  • The Court reiterated that alibi is a weak defense, especially wi...continue reading

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