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PEOPLE v. BOISAN CABUGATAN Y MACARAMBON

This case has been cited 33 times or more.

2015-11-23
MENDOZA, J.
The time-honored rule is that "the issue of credibility of witnesses is a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, xxx and absent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded, which when considered would have affected the outcome of the case."[11] This rule finds an even more stringent application where the said findings are sustained by the CA.[12]
2015-01-12
PERALTA, J.
In connection therewith, one must not forget the well entrenched rule that findings of facts of the trial court, its calibration of the testimonial evidence of the parties as well as its conclusion on its findings, are accorded high respect if not conclusive effect. This is because of the unique advantage of the trial court to observe, at close range, the conduct, demeanor and deportment of the witness as they testify.[18] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[19]
2013-11-25
MENDOZA, J.
Jurisprudence has been consistent that the issue of credibility of witnesses is a question best addressed to the province of the trial court because of its unique position to observe that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying. Absent any substantial reason to justify the reversal of the trial court's assessment and conclusion, the reviewing court is generally bound by the former's findings, particularly when no significant fact or circumstance is shown to have been overlooked or disregarded, which if considered would have affected the outcome of the case.[17] The rule finds an even more stringent application where said findings are sustained by the CA.[18]
2011-06-08
VELASCO JR., J.
For the prosecution of illegal sale of drugs to prosper, the following elements must be proved: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and its payment.  What is material is the proof that the transaction actually took place, coupled with the presentation before the court of the corpus delicti.[18]
2011-02-23
MENDOZA, J.
Time and again, the Court has held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality. The trial judge has the advantage of observing the witness' deportment and manner of testifying. Her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath"[19] are all useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if witnesses are telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[20] The rule finds an even more stringent application where said findings are sustained by the CA.[21]
2010-08-16
PEREZ, J.
A buy-bust operation is a form of entrapment which in recent years has been accepted as a valid and effective mode of apprehending drug pushers.[14]  If carried out with due regard for constitutional and legal safeguards, a buy-bust operation, such as the one involving appellant, deserves judicial sanction. Consequently, the warrantless arrest and warrantless search and seizure conducted on the person of appellant were allowed under the circumstances.  The search, incident to his lawful arrest, needed no warrant to sustain its validity.[15]  Thus, there is no doubt that the sachets of shabu recovered during the legitimate buy-bust operation, are admissible and were properly admitted in evidence against him.[16]
2010-07-05
VILLARAMA, JR., J.
Also undeserving of serious consideration is appellant's defense that there was no buy-bust operation.The trial court found undeserving of credence appellant's self-serving testimony and defense witness Chona Martin's assertion that it was merely by chance that she saw appellant and pointed him to the police officers as the person peddling illegal drugs.  The trial court, in fact, branded Chona Martin's testimony as obviously fabricated.[35]  It is a fundamental rule that findings of the trial courts which are factual in nature and which involve credibility are accorded respect when no glaring errors, gross misapprehension of facts and speculative, arbitrary and unsupported conclusions can be gathered from such findings.The reason for this is that the trial court is in a better position to decide the credibility of witnesses, having heard their testimonies and observed their deportment and manner of testifying during the trial.[36]The rule finds an even more stringent application where said findings are sustained by the CA.[37]As there appears no cogent reason to depart from the findings of the trial court and the CA, we stand by their findings.
2010-06-29
MENDOZA, J.
In this jurisdiction, the conduct of a buy-bust operation is a common and accepted mode of apprehending those involved in illegal sale of prohibited or regulated drugs. It has been proven to be an effective way of unveiling the identities of drug dealers and of luring them out of obscurity.[15] Unless there is clear and convincing evidence that the members of the buy-bust team were impelled by any improper motive or were not properly performing their duty, their testimonies on the operation deserve full faith and credit.[16]
2010-02-22
DEL CASTILLO, J.
It is a fundamental rule that the trial court's findings that are factual in nature and that involve credibility are accorded respect when no glaring errors; gross misapprehension of facts; or speculative, arbitrary and unsupported conclusions can be gathered from such findings.[20] The rule finds an even more stringent application where said findings are sustained by the CA.[21] However, this rule will not apply in this case. As will be discussed shortly, the courts below overlooked two significant and substantial facts which if considered, as we do now consider, will affect the outcome of the case.
2009-07-31
QUISUMBING, J.
First, the trial court did not err in appreciating the testimonies of the prosecution eyewitnesses. The legal aphorism is that the findings of facts of the trial court, its calibration of the testimonial evidence, its assessment of the probative weight thereof as well as its conclusions anchored on the said findings are accorded high respect if not conclusive effect by the appellate courts. The raison d' être for this principle is that the trial court is able to observe and monitor, at close range, the conduct, behavior and deportment of the witnesses as they testify.[21] In fact, the rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[22]
2009-06-30
QUISUMBING, J.
While appellant interposes the defense of frame-up, we view such claim with disfavor as it can easily be fabricated and is commonly used as a facile refuge in drug cases.[13] In cases involving violations of the Dangerous Drugs Act, credence is given to the narration of the incident by the prosecution witnesses especially when they are police officers who are presumed to have performed their duties in a regular manner, unless there is evidence to the contrary.[14]
2009-06-22
CHICO-NAZARIO, J.
We find the testimonies of PO1 Marchan and PO2 Germodo credible and straightforward. It is a fundamental rule that the trial court's findings that are factual in nature and that involve credibility are accorded respect when no glaring errors; gross misapprehension of facts; or speculative, arbitrary and unsupported conclusions can be gathered from such findings. The reason for this is that the trial court was in a better position to decide the credibility of witnesses, having heard their testimonies and observed their deportment and manner of testifying during the trial.[25] The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[26] There being no compelling reasons to deviate from the findings of the trial court and the Court of Appeals, we stick by their findings.
2009-06-16
PUNO, C.J.
The findings of the trial courts carry great weight and respect and, generally, appellate courts will not overturn said findings unless the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which will alter the assailed decision or affect the result of the case.[38]  The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[39]
2009-04-24
CHICO-NAZARIO, J.
Furthermore, accused-appellant questioned the findings of facts made by the trial court. In People v. Dumadag,[19] this Court held that well entrenched is the rule that findings of facts of the trial court, its calibration of the testimonial evidence of the parties as well as its conclusion on its findings, are accorded high respect if not conclusive effect. This is because of the unique advantage of the trial court to observe, at close range, the conduct, demeanor and deportment of the witness as they testify. The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[20] There being no compelling reason to deviate from the findings of both lower courts, we uphold the same.
2008-10-17
CHICO-NAZARIO, J.
This interdiction against warrantless searches and seizures, however, is not absolute and such warrantless searches and seizures have long been deemed permissible by jurisprudence in instances of (1) search of moving vehicles, (2) seizure in plain view, (3) customs searches, (4) waiver or consented searches, (5) stop and frisk situations (Terry search), and search incidental to a lawful arrest. The last includes a valid warrantless arrest, for, while as a rule, an arrest is considered legitimate [if] effected with a valid warrant of arrest, the Rules of Court recognize permissible warrantless arrest, to wit: (1) arrest in flagrante delicto, (2) arrest effected in hot pursuit, and (3) arrest of escaped prisoners.[35]
2008-09-30
CHICO-NAZARIO, J.
It is well-entrenched that the findings of the trial court on the credibility of witness deserve great weight, given the clear advantage of a trial judge in the appreciation of testimonial evidence. We have recognized that the trial court is in the best position to assess the credibility of witnesses and their testimonies because of its unique opportunity to observe the witnesses first-hand; and to note their demeanor, conduct and attitude under grueling examination. These are significant factors in evaluating the sincerity of witnesses, in the process of unearthing the truth.[24] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[25] Thus, except for compelling reasons, we are doctrinally bound by the trial court's assessment of the credibility of witnesses.[26] In this case, there was no cogent reason to deviate from the findings of both lower courts.
2008-09-25
CHICO-NAZARIO, J.
It is well-entrenched that the findings of the trial court on the credibility of witness deserve great weight, given the clear advantage of a trial judge in the appreciation of testimonial evidence. We have recognized that the trial court is in the best position to assess the credibility of witnesses and their testimonies because of their unique opportunity to observe the witnesses first-hand; and to note their demeanor, conduct and attitude under grueling examination. These are significant factors in evaluating the sincerity of witnesses, in the process of unearthing the truth.[26] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[27] Thus, except for compelling reasons, we are doctrinally bound by the trial court's assessment of the credibility of witnesses.[28] In this case, there was no cogent reason to deviate from the findings of both lower courts.
2008-07-28
CHICO-NAZARIO, J.
In this jurisdiction, the conduct of a buy-bust operation is a common and accepted mode of apprehending those involved in illegal sale of prohibited or regulated drugs.  It has been proven to be an effective way of unveiling the identities of drug dealers and of luring them out of obscurity.[59]  Unless there is clear and convincing evidence that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty, their testimonies on the operation deserve full faith and credit.[60]
2008-06-27
CHICO-NAZARIO, J.
We find their claim untenable.  In this jurisdiction, the conduct of a buy-bust operation is a common and accepted mode of apprehending those involved in the illegal sale of prohibited or regulated drugs. It has been proven to be an effective way of unveiling the identities of drug dealers and of luring them out of obscurity.[35]  Unless there is clear and convincing evidence that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty, their testimonies on the operation deserve full faith and credit.[36]
2008-06-27
CHICO-NAZARIO, J.
The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[39] Finding no reason to deviate from the findings of both the trial court and the Court of Appeals, we uphold their findings.
2008-06-26
CHICO-NAZARIO, J.
Fundamental is the principle that findings of the trial courts which are factual in nature and which involve the credibility of witnesses are accorded respect when no glaring errors; gross misapprehension of facts; and speculative, arbitrary and unsupported conclusions can be gathered from such findings.  The reason for this is that the trial court is in a better position to decide the credibility of witnesses, having heard their testimonies and observed their deportment and manner of testifying during the trial.  The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[50]
2008-06-17
CHICO-NAZARIO, J.
Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[43] The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[44]
2008-06-17
CHICO-NAZARIO, J.
The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[29] Finding no compelling reason to depart from the findings of both the trial court and the Court of Appeals, this Court affirms the same.
2008-04-23
CHICO-NAZARIO, J.
The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[27]  Finding no compelling reason to depart from the findings of both the trial court and the Court of Appeals, we affirm their findings.
2008-04-22
CHICO-NAZARIO, J.
The issue of credibility has, time and again, been settled by this Court as a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts.  Absent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances were shown to have been overlooked or disregarded which when considered would have affected the outcome of the case.[40]  The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[41]
2008-03-03
CHICO-NAZARIO, J.
Sexual crimes where the culprit denies culpability is actually a test of credibility. The issue of credibility has, time and again, been settled by this Court as a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts. Absent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case.[34] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[35]
2008-02-19
CHICO-NAZARIO, J.
Moreover, the trial judge's assessment of the credibility of witnesses' testimonies is, as has repeatedly been held by this Court, accorded great respect on appeal in the absence of grave abuse of discretion on its part, it having had the advantage of actually examining both real and testimonial evidence including the demeanor of the witnesses.  The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[51]  In the case at bar, no cogent reason can be appreciated to warrant a departure from the findings of the trial court with respect to the assessment of AAA's testimony, the same being clear, unequivocal and credible.
2007-12-17
CHICO-NAZARIO, J.
Accordingly, the primordial consideration in a determination concerning the crime of rape is the credibility of complainant's testimony.[35] Time and again, we have held that when it comes to the issue of credibility of the victim or the prosecution witnesses, the findings of the trial courts carry great weight and respect and, generally, the appellate courts will not overturn the said findings unless the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which will alter the assailed decision or affect the result of the case.[36]  This is so because trial courts are in the best position to ascertain and measure the sincerity and spontaneity of witnesses through their actual observation of the witnesses' manner of testifying, their demeanor and behavior in court.[37]  Trial judges enjoy the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity.  Trial judges, therefore, can better determine if such witnesses are telling the truth, being in the ideal position to weigh conflicting testimonies. Again, unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected, for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[38]  The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[39]
2007-11-28
CHICO-NAZARIO, J.
It is a fundamental rule that findings of the trial courts which are factual in nature and which involve the credibility of witnesses are accorded respect when no glaring errors, gross misapprehension of facts and speculative, arbitrary and unsupported conclusions can be gathered from such findings. The reason for this being that the trial court is in a better position to decide the credibility of witnesses, having heard their testimonies and observed their deportment and manner of testifying during the trial. The rule finds an even more stringent application where said findings are sustained by the Court of Appeals as in this case.[21] After a review of the records, we find no compelling reason to reverse the findings of the trial court, as affirmed by the Court of Appeals.
2007-09-28
CHICO-NAZARIO, J.
It is well-entrenched that the findings of the trial court on the credibility of a witness deserve great weight, given the clear advantage of a trial judge in the appreciation of testimonial evidence.  We have recognized that the trial court is in the best position to assess the credibility of witnesses and their testimonies, because of their unique opportunity to observe the witnesses first hand and to note their demeanor, conduct, and attitude under grueling examination.  These are significant factors in evaluating the sincerity of witnesses, in the process of unearthing the truth.[13]  The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[14]  Thus, except for compelling reasons, we are doctrinally bound by the trial court's assessment of the credibility of witnesses.[15]
2007-09-05
CHICO-NAZARIO, J.
Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case.  The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" - all of which are useful aids for an accurate determination of a witness' honesty and sincerity.  The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they are lying.[42]  The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[43]
2007-08-31
CHICO-NAZARIO, J.
In this jurisdiction, the conduct of a buy-bust operation is a common and accepted mode of apprehending those involved in the illegal sale of prohibited or regulated drugs. It has been proven to be an effective way of unveiling the identities of drug dealers and of luring them out of obscurity.[49] Unless there is clear and convincing evidence that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty, their testimonies on the operation deserve full faith and credit.[50]
2007-08-08
CARPIO MORALES, J.
In any event, the warrantless arrest of appellant is justified under Rule 113, Section 5(a) of the Rules of Court[16] which reads:SEC. 5. Arrest without warrant; when lawful. - A peace officer or a private person may, without a warrant, arrest a person: