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, ...

Facts:

Background of the Case
The case involves appellant Jacinto Lantano, who was convicted of raping his 14-year-old daughter, AAA. The incident allegedly occurred between April 1998 and January 1999 in Tagudin, Ilocos Sur. Appellant was charged with rape under Articles 266-A and 266-B of the Revised Penal Code, as amended by Republic Act (R.A.) No. 8353, in relation to R.A. No. 7610 and R.A. No. 7659.

The Incident
On April 11, 1998, AAA was lying in bed due to a headache when appellant approached her, kissed her cheek, and uttered words expressing his longing for her mother. He then placed a knife beside her, pulled down her shorts, removed his own clothing, and proceeded to rape her. AAA resisted but was overpowered by appellant, who warned her not to tell anyone or he would kill her.

Aftermath and Reporting
AAA remained silent due to fear but later informed her mother, who was working abroad, about her deteriorating health. In January 1999, AAA was brought to Ilocos Norte, where she eventually disclosed the rape to her grandfather, who reported the incident to the police. AAA underwent a medical examination, which confirmed lacerations consistent with rape.

Defense's Argument
Appellant denied the accusation, claiming he was not at home during the alleged incident. He presented alibi evidence, stating he was at the river working on an artificial reef. His mother and nephew corroborated his alibi.

Trial Court Decision
The Regional Trial Court found appellant guilty beyond reasonable doubt of rape aggravated by relationship and minority and sentenced him to death. The Court also ordered him to pay civil indemnity, moral damages, and exemplary damages.

Appeal and Court of Appeals Decision
The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua, considering the abolition of the death penalty under R.A. No. 9346.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Delay in Reporting Rape
   The Court held that delay in reporting rape, especially in cases of incestuous rape, is justified due to fear and intimidation. Appellant's moral ascendancy as a father and his threats of harm effectively silenced AAA.

2. Credibility of AAA's Testimony
   Minor inconsistencies in AAA's testimony, such as confusion about the exact date of the rape, do not undermine her credibility. Rape victims are not expected to recount events with perfect accuracy.

3. Alibi and Denial
   Appellant's alibi was insufficient to exonerate him. The proximity of the river to his house made it physically possible for him to be at the scene of the crime. Denial, being a negative defense, cannot prevail over AAA's positive and categorical testimony.

4. Penalty and Damages
   The Court upheld the penalty of reclusion perpetua, consistent with prevailing jurisprudence. The award of moral damages was increased to PHP 75,000 to reflect the gravity of the offense and the suffering endured by the victim.