Title
People vs. Mirante Sr.
Case
G.R. No. 147606
Decision Date
Jan 14, 2003
A father convicted of raping his 14-year-old daughter; Supreme Court reduced death penalty to reclusion perpetua due to insufficient proof of victim's age.

Case Summary (G.R. No. 157163)

Factual Background

Rogelio Mirante Sr. was found guilty by the Regional Trial Court of raping his daughter, AAA, on two occasions: November 28, 1998, and February 25, 1999. AAA provided a detailed and emotional testimony about the sexual abuse she suffered, describing the incidents where her father forcibly stripped her and sexually assaulted her while threatening her with a weapon. Despite repeated attempts to confide in her mother about the abuse, AAA was met with disbelief and denial, as her mother sided with Rogelio.

Evidence and Testimonies

The prosecution presented testimonies from AAA and medical evidence that outlined the physical condition of AAA's genitalia, confirming previous sexual abuse. Although Rogelio asserted a defense based on alibi and denial, claiming he was away from home during the incidents, the trial court found AAA's testimony credible and consistent. The inconsistencies raised by the defense regarding AAA's statements were deemed minor and did not undermine the truth of her allegations.

Legal Considerations and Court Findings

For Rogelio to be convicted of qualified rape, it must be established that AAA was a minor, specifically under eighteen years of age, at the time of the offenses. The conviction relied solely on AAA's age testimony, as no birth certificate or corroborative documentation demonstrating her age was submitted as evidence. Thus, the court concluded that the prosecution failed to prove that she was underage, leading to a conviction for simple rape rather than qualified rape.

Sentencing and Damages

Subsequently, the trial court sentenced Rogelio Mirante Sr. to death, but this was modified upon appeal. The conviction for simple rape prompted a reduction of the penalty to reclusion perpetua due to the insufficient evidenc

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