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
Case Digest (G.R. No. 176734)
Facts:
The case involves Jacinto Lantano, the appellant, who was convicted of raping his fourteen-year-old daughter, referred to as AAA. The events took place between April 1998 and January 1999 in Tagudin, Ilocos Sur, Philippines. The Regional Trial Court of Tagudin, Branch 25, found Lantano 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 Act Nos. 7610 and 7659. The Information filed against him stated that he had carnal knowledge of AAA through force and intimidation, aggravated by their familial relationship.
During the trial, AAA testified that on April 11, 1998, while suffering from a headache and lying in bed with her younger sibling, her father approached her, kissed her, and made a disturbing statement about missing her mother. He then threatened her with a knife, forcibly removed her clothing, and raped her. Despite her attempts to resist, Lantano overpowered her, and after the assault, he warned her not to tell anyone, threatening her life. Following the incident, AAA remained silent due to fear and confusion, only revealing her ordeal to her mother, who was working abroad, through letters. Eventually, she disclosed the incident to her grandfather, leading to a police report and medical examination that confirmed signs of rape.
Lantano's defense was based on an alibi, claiming he was fishing with relatives at the time of the incident. However, the trial court found his alibi unconvincing and ruled in...