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PEOPLE v. CONRADO LAOG Y RAMIN

This case has been cited 8 times or more.

2015-06-22
VILLARAMA, JR., J.
This Court has reiterated that the credibility of witnesses is a question best addressed by the trial court because of its opportunity to observe their demeanor while testifying on the stand: an opportunity denied to the appellate courts.[24] 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, especially when no significant fact nor circumstance is shown to have been overlooked or disregarded which when considered could affect the outcome of the case.[25] The rule is strictly applied when the appellate court affirms the finding of the lower court.
2014-08-06
REYES, J.
Finally, pursuant to People v. Laog,[30] the award of exemplary damages is increased to P30,000.00 per crime in view of the aggravating circumstances of minority and relationship.
2014-07-23
REYES, J.
In the physical examination performed after the second rape incident, Dr. Sumabat found lacerations in AAA's hymen. The accused-appellant alleged that there were inconsistencies in the dates of the commission of the crime, on one hand, and the conduct of the physical examination, on the other. However, this stance, taken together with the accused-appellant's uncorroborated defenses of denial and alibi, pales vis-à-vis AAA's positive testimony and the medical evidence which prove that, indeed, AAA's hymen sustained lacerations, albeit healed. As we held in People v. Laog,[26]
2014-06-30
REYES, J.
Anent the supposed inconsistencies in the testimony of AAA, suffice it to say that "[d]iscrepancies referring only to minor details and collateral matters not to the central fact of the crime do not affect the veracity or detract from the essential credibility of witnesses' declarations, as long as these are coherent and intrinsically believable on the whole. For a discrepancy or inconsistency in the testimony of a witness to serve as a basis for acquittal, it must establish beyond doubt the innocence of the appellant for the crime charged. It cannot be overemphasized that the credibility of a rape victim is not diminished, let alone impaired, by minor inconsistencies in her testimony."[19]
2013-07-17
PEREZ, J.
Moreover, it has been emphasized that an affidavit taken ex-parte is generally unreliable as oftentimes it is inaccurate.[13] This underscores the weight of the clarification that the prosecution witness made during the trial. Indeed, discrepancies on minor details do not erase but enhance the credibility of either the witness or his testimony. As aptly cited in People v. Cabtalan,[14] minor inconsistencies and discrepancies pertaining to trivial matters do not affect the credibility of witnesses, as well as their positive identification of the accused as the perpetrator of the crime. Similarly, as held in the case of People v. Laog,[15] where the appellant also raised the inconsistencies in the testimony of the victim, this Court declared: Nonetheless, this matter raised by appellant is a minor detail which had nothing to do with the elements of the crime of rape. Discrepancies referring only to minor details and collateral matters not to the central fact of the crime do not affect the veracity or detract from the essential credibility of witnesses' declarations, as long as these are coherent and intrinsically believable on the whole.[16]
2013-07-17
VILLARAMA, JR., J.
Regarding the award of damages, we affirm the trial court and CA in ordering the petitioner to pay the heirs of Generoso Hispano the amount of P50,000 as moral damages. In cases of murder and homicide, the award of moral damages is mandatory, without need of allegation and proof other than the death of the victim.[32] Similarly, the CA correctly awarded his heirs the amount of P171,128.75 as actual damages, as said amount which was spent for funeral and burial expenses was duly supported by receipts. However, as regards the award of civil indemnity, the same should be increased to P75,000 to conform with recent jurisprudence.[33] Also, the heirs of the victim are entitled to exemplary damages which recent jurisprudence pegs at P30,000[34] considering the presence of the aggravating circumstance of treachery. Lastly, we impose on all the monetary awards for damages interest at the legal rate of 6% per annum from date of finality of this Decision until fully paid, consistent with current policy.
2012-02-08
BRION, J.
First, the Court gives the highest respect to the RTC's evaluation of the testimony of the witnesses, considering its unique position in directly observing the demeanor of a witness on the stand.  From its vantage point, the trial court is in the best position to determine the truthfulness of witnesses.[10]
2012-02-01
PEREZ, J.
In the case of People v. Laog,[15] where the appellant also raised the inconsistencies in the testimony of the victim, this Court declared: Nonetheless, this matter raised by appellant is a minor detail which had nothing to do with the elements of the crime of rape. Discrepancies referring only to minor details and collateral matters -- not to the central fact of the crime -- do not affect the veracity or detract from the essential credibility of witnesses' declarations, as long as these are coherent and intrinsically believable on the whole.[16] For a discrepancy or inconsistency in the testimony of a witness to serve as a basis for acquittal, it must establish beyond doubt the innocence of the appellant for the crime charged.[17] It cannot be overemphasized that the credibility of a rape victim is not diminished, let alone impaired, by minor inconsistencies in her testimony.[18]