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.