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GR No. 192232

2014-12-10

DEL CASTILLO, J.

In any case, this Court has already concluded that a medical report is not even material for purposes of proving rape as it is merely corroborative in character and, thus, can be dispensed with accordingly.[38] In fact, the Court has consistently maintained that:x x x The medical report is by no means controlling. This Court has repeatedly held that a medical examination of the victim is not indispensable in the prosecution for rape, and no law requires a medical examination for the successful prosecution thereof. The medical examination of the victim or the presentation of the medical certificate is not essential to prove the commission of rape as the testimony of the victim alone, if credible, is sufficient to convict the accused of the crime. The medical examination of the victim as well as the medical certificate is merely corroborative in character.[39] (Emphasis supplied)

GR No. 200645

2014-08-20

PEOPLE v. WENDEL OCDOL Y MENDOVA

PEREZ, J.

Again, by way of emphasis, we adhere to the rule that due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding.[26]

GR No. 194833

2014-07-02

PEOPLE v. PORFERIO BALINO

PEREZ, J.

This Court is not unaware that due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding.[16]

GR No. 202842

2013-10-09

PEOPLE v. FLORENTINO GALAGAR

REYES, J.

As to the failure of AAA to present a medical certificate or report, the Court has consistently held that in proving rape the medical examination of the victim or the presentation of a medical report is not essential. The victim's testimony alone, if credible, is sufficient to convict the accused of the crime. The medical examination of the victim and the corresponding medical certificate are merely corroborative pieces of evidence.[22]

GR No. 197363

2013-06-26

PEOPLE v. ROMAN ZAFRA Y SERRANO

LEONARDO-DE CASTRO, J.

Zafra's defense of denial must necessarily fail. It is a well-settled doctrine that such defense will only prosper upon the presentation of clear and convincing evidence substantiating it. Otherwise, it is a self-serving assertion that deserves no weight in law, and which cannot prevail over the positive, candid, and categorical testimony of the complainant.[40]

GR No. 183091

2013-06-19

PEOPLE v. BERNESTO DE LA CRUZ

SERENO, C.J.

In People v. Dion[21] we stated that:Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted, emphasis added.) Given that in the present case, the courts a quo have sufficiently addressed the question on the alleged inconsistencies in the testimony of BBB and appellant does not present to this Court any scintilla of evidence to prove that the testimony of the witness was not credible, the Court must uphold the identical assessment of the RTC as affirmed by the Court of Appeals. In any event, the alleged inconsistencies in the testimonies of the prosecution's witnesses did not detract from BBB's credibility as a witness.

GR No. 187740

2013-04-10

PEOPLE OF PHILIPPINES v. MANUEL CATACUTAN

PEREZ, J.

The legal adage that when a woman, especially a girl-child, says she had been raped, she says in effect all that is necessary to prove that rape was really committed, finds yet another application in this case.[26] The rationale of this jurisprudential principle is that, "no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subjected to public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her."[27]

GR No. 188849

2013-02-13

PEOPLE v. JONATHAN 'UTO' VELOSO Y RAMA

LEONARDO-DE CASTRO, J.

In dealing with cases for rape, this Court has often acknowledged that there is often a want of witnesses. In People v. Dion,[20] this Court said that: Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted, emphasis added.)

GR No. 186463

2012-11-14

PEOPLE v. WILLIAM MANGUNE Y DEL ROSARIO

LEONARDO-DE CASTRO, J.

Expounding on the matter, this Court, in People v. Dion,[37] said: Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted.)

GR No. 191365

2012-02-22

PEOPLE v. EDUARDO NAVARETTE

PEREZ, J.

The Court of Appeals opined that "errorless testimony cannot be expected of a rape victim for she may not be able to remember or recount every ugly detail of the harrowing experience and appalling outrage she went through, especially so since she might in fact be trying not to recall the same, as they are too painful to remember." Indeed, it is doctrinal that date or time of the commission of rape is not a material ingredient of the said crime because the gravamen of rape is carnal knowledge of a woman through force and intimidation. The precise time when the rape took place has no substantial bearing on its commission.[22] In statutory rape, time is not an essential element. What is important is that the information alleges that the victim was a minor under twelve years of age and that the accused had carnal knowledge of her, even if the accused did not use force or intimidation on her or deprived her of reason.[23]

	GR No. 192232 2014-12-10	PEOPLE v. JOSE ESTALIN PRODENCIADO DEL CASTILLO, J.
In any case, this Court has already concluded that a medical report is not even material for purposes of proving rape as it is merely corroborative in character and, thus, can be dispensed with accordingly.[38] In fact, the Court has consistently maintained that:x x x The medical report is by no means controlling. This Court has repeatedly held that a medical examination of the victim is not indispensable in the prosecution for rape, and no law requires a medical examination for the successful prosecution thereof. The medical examination of the victim or the presentation of the medical certificate is not essential to prove the commission of rape as the testimony of the victim alone, if credible, is sufficient to convict the accused of the crime. The medical examination of the victim as well as the medical certificate is merely corroborative in character.[39] (Emphasis supplied)
	GR No. 200645 2014-08-20	PEOPLE v. WENDEL OCDOL Y MENDOVA PEREZ, J.
Again, by way of emphasis, we adhere to the rule that due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding.[26]
	GR No. 194833 2014-07-02	PEOPLE v. PORFERIO BALINO PEREZ, J.
This Court is not unaware that due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding.[16]
	GR No. 202842 2013-10-09	PEOPLE v. FLORENTINO GALAGAR REYES, J.
As to the failure of AAA to present a medical certificate or report, the Court has consistently held that in proving rape the medical examination of the victim or the presentation of a medical report is not essential. The victim's testimony alone, if credible, is sufficient to convict the accused of the crime. The medical examination of the victim and the corresponding medical certificate are merely corroborative pieces of evidence.[22]
	GR No. 197363 2013-06-26	PEOPLE v. ROMAN ZAFRA Y SERRANO LEONARDO-DE CASTRO, J.
Zafra's defense of denial must necessarily fail. It is a well-settled doctrine that such defense will only prosper upon the presentation of clear and convincing evidence substantiating it. Otherwise, it is a self-serving assertion that deserves no weight in law, and which cannot prevail over the positive, candid, and categorical testimony of the complainant.[40]
	GR No. 183091 2013-06-19	PEOPLE v. BERNESTO DE LA CRUZ SERENO, C.J.
In People v. Dion[21] we stated that:Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted, emphasis added.) Given that in the present case, the courts a quo have sufficiently addressed the question on the alleged inconsistencies in the testimony of BBB and appellant does not present to this Court any scintilla of evidence to prove that the testimony of the witness was not credible, the Court must uphold the identical assessment of the RTC as affirmed by the Court of Appeals. In any event, the alleged inconsistencies in the testimonies of the prosecution's witnesses did not detract from BBB's credibility as a witness.
	GR No. 187740 2013-04-10	PEOPLE OF PHILIPPINES v. MANUEL CATACUTAN PEREZ, J.
The legal adage that when a woman, especially a girl-child, says she had been raped, she says in effect all that is necessary to prove that rape was really committed, finds yet another application in this case.[26] The rationale of this jurisprudential principle is that, "no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subjected to public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her."[27]
	GR No. 188849 2013-02-13	PEOPLE v. JONATHAN 'UTO' VELOSO Y RAMA LEONARDO-DE CASTRO, J.
In dealing with cases for rape, this Court has often acknowledged that there is often a want of witnesses. In People v. Dion,[20] this Court said that: Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted, emphasis added.)
	GR No. 186463 2012-11-14	PEOPLE v. WILLIAM MANGUNE Y DEL ROSARIO LEONARDO-DE CASTRO, J.
Expounding on the matter, this Court, in People v. Dion,[37] said: Due to its intimate nature, rape is usually a crime bereft of witnesses, and, more often than not, the victim is left to testify for herself. Thus, in the resolution of rape cases, the victim's credibility becomes the primordial consideration. It is settled that when the victim's testimony is straightforward, convincing, and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility, and the accused may be convicted solely on the basis thereof. Inconsistencies in the victim's testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential fact of the commission of rape. The trial court's assessment of the witnesses' credibility is given great weight and is even conclusive and binding. x x x. (Citations omitted.)
	GR No. 191365 2012-02-22	PEOPLE v. EDUARDO NAVARETTE PEREZ, J.
The Court of Appeals opined that "errorless testimony cannot be expected of a rape victim for she may not be able to remember or recount every ugly detail of the harrowing experience and appalling outrage she went through, especially so since she might in fact be trying not to recall the same, as they are too painful to remember." Indeed, it is doctrinal that date or time of the commission of rape is not a material ingredient of the said crime because the gravamen of rape is carnal knowledge of a woman through force and intimidation. The precise time when the rape took place has no substantial bearing on its commission.[22] In statutory rape, time is not an essential element. What is important is that the information alleges that the victim was a minor under twelve years of age and that the accused had carnal knowledge of her, even if the accused did not use force or intimidation on her or deprived her of reason.[23]

PEOPLE v. NOEL DION