Title
People vs. Lantano
Case
G.R. No. 176734
Decision Date
Jan 28, 2008
A father convicted of raping his 14-year-old daughter; delay in reporting due to fear; alibi rejected; reclusion perpetua upheld; damages increased.
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Case Summary (G.R. No. 176734)

Context of the Case

  • The case involves the conviction of Jacinto Lantano for the crime of rape against his fourteen-year-old daughter, AAA.
  • The crime occurred between April 1998 and January 1999 in Tagudin, Ilocos Sur, Philippines.
  • The charges were based on Articles 266-A and 266-B of the Revised Penal Code, as amended by Republic Acts No. 8353, 7610, and 7659.
  • The prosecution's case was primarily built on AAA's testimony, which described the traumatic events she endured.

Testimony of the Victim

  • On April 11, 1998, AAA was lying in bed due to a headache when her father approached her.
  • Appellant kissed her and made a disturbing statement about missing her mother before he assaulted her.
  • He used a knife to intimidate her, forcibly removed her clothing, and raped her despite her resistance.
  • After the assault, he threatened her life if she disclosed the incident, instilling fear that led her to remain silent.

Reporting the Incident

  • AAA eventually confided in her mother, who was working abroad, about her deteriorating condition.
  • After being brought to her grandparents in Piddig, Ilocos Norte, she disclosed the rape to her grandfather, who reported it to the police.
  • A medical examination confirmed physical evidence of rape, including lacerations consistent with the assault.

Defense and Alibi

  • The appellant's defense was based on an alibi, claiming he was fishing with relatives at the time of the incident.
  • Witnesses testified to his whereabouts, but the trial court found their accounts insufficient to establish his absence from the scene.
  • The trial court emphasized that the proximity of the river to their home made it plausible for him to have committed the crime.

Trial Court's Findings

  • The trial court found AAA's testimony credible and consistent, despite her initial silence and delay in reporting.
  • It ruled that her fear of her father and the threats he made justified her delayed disclosure.
  • The court sentenced Lantano to death, citing the aggravating circumstances of relationship and minority.

Court of Appeals Decision

  • The Court of Appeals affirmed the trial court's conviction but modified the penalty to reclusion perpetua.
  • The appellate court upheld the monetary awards for civil indemnity and damages, adjusting the moral damages to P75,000.

Appellant's Arguments on Appeal

  • Lantano argued that the delay in reporting the rape undermined AAA's credibility and suggested fabrication.
  • He claimed that the threats were not imminent and that AAA could have sought help during the assault.
  • The appellant also suggested that AAA was influenced by her maternal grandparents to fabricate the charges.

Prosecution's Response

  • The Office of the Solicitor General countered that AAA's delay was adequately explained by her fear and the psychological impact of the assault.
  • It asserted that the credibility of AAA's testimony should prevail over Lantano's denial and alibi.

Supreme Court's Ruling

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