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GR No. 191972

2015-01-26

LEONEN, J.

This is a Petition[3] for certiorari, prohibition, and mandamus with application for preliminary and/or mandatory injunction to set aside the Court of Appeals' Entry of Judgment[4] in CA-G.R. CR No. 24368, and the Regional Trial Court, Branch 58, Cebu City's Order[5] dated March 25, 2004 and Order of Detention[6] dated February 15, 2010 in Criminal Case No. CBU-48773.[7]

GR No. 180499

2008-07-09

PEOPLE v. CONRADO CACAYAN

TINGA, J,

In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted solely on that basis.[35] We have thoroughly examined AAA's testimony and find nothing that would cast doubt as to her credibility. All said, there is no evidence to show any improper motive on the part of AAA to falsely charge appellant with rape and to testify against him; hence, the logical conclusion is that her testimony is worthy of full faith and credence. The prosecution has established beyond reasonable doubt that appellant had carnal knowledge of AAA against her will, through force and intimidation, and with the use of a bolo.

GR No. 176265

2008-04-30

PEOPLE v. JOSE MAGBANUA Y MORIÑO

TINGA, J,

In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted solely on that basis. [25] We have thoroughly examined AAA's testimony and find nothing that would cast doubt as to her credibility. All said, there is no evidence to show any improper motive on the part of AAA to falsely charge appellant with rape and to testify against him; hence, the logical conclusion is that her testimony is worthy of full faith and credence. The prosecution has established beyond reasonable doubt that appellant had carnal knowledge of AAA against her will, through force and intimidation, and with the use of a fan knife.

GR No. 179477

2008-02-06

PEOPLE v. JIMMY TABIO

TINGA, J,

Our courts have been traditionally guided by three settled principles in the prosecution of the crime of rape: (1) an accusation for rape is easy to make, difficult to prove and even more difficult to disprove; (2) in view of the intrinsic nature of the crime, the testimony of the complainant must be scrutinized with utmost caution; and (3) the evidence of the prosecution must stand on its own merits and cannot draw strength from the weakness of the evidence of the defense.[24] In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted on the sole basis thereof. [25]

GR No. 132167

2002-01-08

PEOPLE v. ARMANDO QUENING Y VERSOZA

QUISUMBING, J.

It is well settled that in assessing the credibility of witnesses, this Court gives great respect to the evaluation of the trial court for it had the unique opportunity to observe the demeanor of witnesses and their deportment while testifying. Such an opportunity is denied the appellate courts, which rely on the cold pages of the records of the case.[15] Only when such assessment is tainted with arbitrariness or oversight of a significant fact or circumstance that could affect the result will the appellate court depart from the trial court's factual conclusions.[16]

GR No. 131040

2001-10-05

PEOPLE v. MICHAEL FRAMIO SABAGALA

QUISUMBING, J.

Rather than weaken her testimony, said inconsistencies tend to strengthen complainant's credibility as these prove that she was being spontaneous during her narration of the ordeal she suffered at the hands of appellant, an indication that she was not a rehearsed witness.[59] It is too much for us to expect a victim of a heinous crime, such as rape, to narrate her unfortunate experience free from any mistake or error.[60] A rape victim is not and cannot be expected to keep an accurate account of her traumatic experience.[61] A court cannot expect a rape victim to remember every ugly detail of the appalling outrage, especially so since she might in fact have been trying not to remember them.[62] Moreover, it must be remembered that the victim was only a 14-year old barrio lass, far from being a sophisticated woman who could be expected to weigh her every word with care so as to be free of inconsistency.

GR No. 139180

2001-07-31

PEOPLE v. ROLANDO RIVERA

MENDOZA, J.

II. Coming now to the merits of this case, we find that the evidence proves beyond reasonable doubt the guilt of accused-appellant. In reviewing rape cases, we have been guided by the following principles: (a) An accusation for rape is easy to make, difficult to prove, and even more difficult to disprove; (b) In view of the intrinsic nature of the crime, the testimony of the complainant must be scrutinized with extreme caution; and (c) The evidence for the prosecution must stand on its own merits and cannot draw strength from the weakness of the evidence for the defense.[49]

GR Nos. 137762-65

2001-03-27

PEOPLE v. REYNALDO BARES Y LONGASA

MENDOZA, J.

It is well settled that the accused in a rape case may be convicted solely on the testimony of the complaining witness, provided that such is credible, natural, convincing, and otherwise consistent with human nature and the normal course of things.[25] In this case, Maribel testified in a direct, unequivocal, and consistent manner with regard to the rapes committed by accused-appellant: Q Sometime on September 8, 1995, while you and your father were staying in Dalas, Labo, Camarines Norte, in the morning at around 1:00 o'clock, do you remember [an] unusual incident that happened to you? A Yes, sir.

GR No. 129238

2001-02-22

PEOPLE v. REGALADO BURLAT Y BANAWA

PARDO, J.

The failure of the victim to immediately report the incident to her family or to the police authorities does not detract from her credibility or indicate a fabricated charge.[14] The six month delay was due to the threats of accused-appellant. It is not uncommon for rape victims to conceal for sometime the assaults on their virtue or person because of the rapist's threats on their lives.[15]

GR Nos. 133586-603

2001-02-19

PEOPLE v. HENRY QUEIGAN

YNARES-SANTIAGO, J.

The Court notes that while the court a quo awarded indemnity ex delicto, which current jurisprudence has fixed at P50,000.00[46] for the offenses committed, no moral damages have been awarded. It must be stressed in this regard that civil indemnity is separate and distinct from the award of moral damages which is automatically granted in rape cases.[47] Pursuant to controlling case law, the award of P50,000.00 ex delicto is mandatory upon the finding of the fact of rape.[48] Moral damages in the amount of P50,000.00[49] are additionally awarded without need of pleading or proof of the basis thereof.[50] This is because it is recognized that the victim's injury is concomitant with and necessarily resulting from the odiousness of the crime to warrant per se the award of moral damages.[51]

GR Nos. 137185-86

2001-02-15

PEOPLE v. SALVADOR MACAYA Y FRANCISCO

BELLOSILLO, J.

The trial court ordered accused-appellant to pay each of his victims an indemnity of P100,000.00, which we find a little excessive, so we reduce the amount to P50,000.00 to be awarded to each of Mercelinda and Angelica. In addition, they are entitled to moral damages in the amount of P50,000.00 each, which is imposed in rape cases without need of showing that the victims suffered mental anguish, fright, serious anxiety and the like.[22]

GR Nos. 137106-07

2001-01-31

PEOPLE v. JOSE ELPEDES Y SUNAS

YNARES-SANTIAGO, J.

The Court notes that the court a quo neither awarded any indemnity ex delicto, which current jurisprudence has fixed at P50,000.00,[44] nor moral damages on account of the rape. It must be stressed in this regard that civil indemnity is separate and distinct from the award of moral damages which is automatically granted in rape cases.[45] Pursuant to controlling case law, the award of P50,000.00 ex delicto is mandatory upon the finding of the fact of rape.[46] Moral damages are additionally awarded without need of pleading or proof of the basis thereof.[47] This is because it is recognized that the victim's injury is concomitant with and necessarily resulting from the odiousness of the crime to warrant per se the award of moral damages.[48]

GR No. 129769

2001-01-19

PEOPLE v. ANTONIO BELGA

YNARES-SANTIAGO, J.

In the case at bar, the trial court has to rely on its own assessment of the credibility of both parties, particularly that of the complainant. Credible witness and credible testimony are the two essential elements for the determination of the weight of a particular testimony. This principle could not ring any truer than in this case where the prosecution relies mainly on the testimony of the complainant, corroborated by the medico-legal findings of a physician.[4] Be that as it may, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and otherwise consistent with human nature.[5]

GR Nos. 137108-09

2000-11-20

PEOPLE v. JONNIE TAGAYLO Y CORTES

DAVIDE JR., C.J.

Anent the civil liability of JONNIE, the trial court merely ordered the payment of civil indemnity in the amount of P50,000 but did not award the payment of moral damages. Thus, in accordance with prevailing jurisprudence, JONNIE should be ordered to pay the amount of P50,000 as moral damages.[24] Moral damages are imposed in rape cases involving young girls between 13 and 19 years of age, taking into account the immeasurable havoc wrought on their youthful feminine psyche. It may be awarded without need of showing that the victim suffered mental anguish, fright, serious anxiety and the like.[25]

	GR No. 191972 2015-01-26	HENRY ONG LAY HIN v. CA LEONEN, J.
This is a Petition[3] for certiorari, prohibition, and mandamus with application for preliminary and/or mandatory injunction to set aside the Court of Appeals' Entry of Judgment[4] in CA-G.R. CR No. 24368, and the Regional Trial Court, Branch 58, Cebu City's Order[5] dated March 25, 2004 and Order of Detention[6] dated February 15, 2010 in Criminal Case No. CBU-48773.[7]
	GR No. 180499 2008-07-09	PEOPLE v. CONRADO CACAYAN TINGA, J,
In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted solely on that basis.[35] We have thoroughly examined AAA's testimony and find nothing that would cast doubt as to her credibility. All said, there is no evidence to show any improper motive on the part of AAA to falsely charge appellant with rape and to testify against him; hence, the logical conclusion is that her testimony is worthy of full faith and credence. The prosecution has established beyond reasonable doubt that appellant had carnal knowledge of AAA against her will, through force and intimidation, and with the use of a bolo.
	GR No. 176265 2008-04-30	PEOPLE v. JOSE MAGBANUA Y MORIÑO TINGA, J,
In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted solely on that basis. [25] We have thoroughly examined AAA's testimony and find nothing that would cast doubt as to her credibility. All said, there is no evidence to show any improper motive on the part of AAA to falsely charge appellant with rape and to testify against him; hence, the logical conclusion is that her testimony is worthy of full faith and credence. The prosecution has established beyond reasonable doubt that appellant had carnal knowledge of AAA against her will, through force and intimidation, and with the use of a fan knife.
	GR No. 179477 2008-02-06	PEOPLE v. JIMMY TABIO TINGA, J,
Our courts have been traditionally guided by three settled principles in the prosecution of the crime of rape: (1) an accusation for rape is easy to make, difficult to prove and even more difficult to disprove; (2) in view of the intrinsic nature of the crime, the testimony of the complainant must be scrutinized with utmost caution; and (3) the evidence of the prosecution must stand on its own merits and cannot draw strength from the weakness of the evidence of the defense.[24] In a prosecution for rape, the complainant's candor is the single most important issue. If a complainant's testimony meets the test of credibility, the accused may be convicted on the sole basis thereof. [25]
	GR No. 132167 2002-01-08	PEOPLE v. ARMANDO QUENING Y VERSOZA QUISUMBING, J.
It is well settled that in assessing the credibility of witnesses, this Court gives great respect to the evaluation of the trial court for it had the unique opportunity to observe the demeanor of witnesses and their deportment while testifying. Such an opportunity is denied the appellate courts, which rely on the cold pages of the records of the case.[15] Only when such assessment is tainted with arbitrariness or oversight of a significant fact or circumstance that could affect the result will the appellate court depart from the trial court's factual conclusions.[16]
	GR No. 131040 2001-10-05	PEOPLE v. MICHAEL FRAMIO SABAGALA QUISUMBING, J.
Rather than weaken her testimony, said inconsistencies tend to strengthen complainant's credibility as these prove that she was being spontaneous during her narration of the ordeal she suffered at the hands of appellant, an indication that she was not a rehearsed witness.[59] It is too much for us to expect a victim of a heinous crime, such as rape, to narrate her unfortunate experience free from any mistake or error.[60] A rape victim is not and cannot be expected to keep an accurate account of her traumatic experience.[61] A court cannot expect a rape victim to remember every ugly detail of the appalling outrage, especially so since she might in fact have been trying not to remember them.[62] Moreover, it must be remembered that the victim was only a 14-year old barrio lass, far from being a sophisticated woman who could be expected to weigh her every word with care so as to be free of inconsistency.
	GR No. 139180 2001-07-31	PEOPLE v. ROLANDO RIVERA MENDOZA, J.
II. Coming now to the merits of this case, we find that the evidence proves beyond reasonable doubt the guilt of accused-appellant. In reviewing rape cases, we have been guided by the following principles: (a) An accusation for rape is easy to make, difficult to prove, and even more difficult to disprove; (b) In view of the intrinsic nature of the crime, the testimony of the complainant must be scrutinized with extreme caution; and (c) The evidence for the prosecution must stand on its own merits and cannot draw strength from the weakness of the evidence for the defense.[49]
	GR Nos. 137762-65 2001-03-27	PEOPLE v. REYNALDO BARES Y LONGASA MENDOZA, J.
It is well settled that the accused in a rape case may be convicted solely on the testimony of the complaining witness, provided that such is credible, natural, convincing, and otherwise consistent with human nature and the normal course of things.[25] In this case, Maribel testified in a direct, unequivocal, and consistent manner with regard to the rapes committed by accused-appellant: Q Sometime on September 8, 1995, while you and your father were staying in Dalas, Labo, Camarines Norte, in the morning at around 1:00 o'clock, do you remember [an] unusual incident that happened to you? A Yes, sir.
	GR No. 129238 2001-02-22	PEOPLE v. REGALADO BURLAT Y BANAWA PARDO, J.
The failure of the victim to immediately report the incident to her family or to the police authorities does not detract from her credibility or indicate a fabricated charge.[14] The six month delay was due to the threats of accused-appellant. It is not uncommon for rape victims to conceal for sometime the assaults on their virtue or person because of the rapist's threats on their lives.[15]
	GR Nos. 133586-603 2001-02-19	PEOPLE v. HENRY QUEIGAN YNARES-SANTIAGO, J.
The Court notes that while the court a quo awarded indemnity ex delicto, which current jurisprudence has fixed at P50,000.00[46] for the offenses committed, no moral damages have been awarded. It must be stressed in this regard that civil indemnity is separate and distinct from the award of moral damages which is automatically granted in rape cases.[47] Pursuant to controlling case law, the award of P50,000.00 ex delicto is mandatory upon the finding of the fact of rape.[48] Moral damages in the amount of P50,000.00[49] are additionally awarded without need of pleading or proof of the basis thereof.[50] This is because it is recognized that the victim's injury is concomitant with and necessarily resulting from the odiousness of the crime to warrant per se the award of moral damages.[51]
	GR Nos. 137185-86 2001-02-15	PEOPLE v. SALVADOR MACAYA Y FRANCISCO BELLOSILLO, J.
The trial court ordered accused-appellant to pay each of his victims an indemnity of P100,000.00, which we find a little excessive, so we reduce the amount to P50,000.00 to be awarded to each of Mercelinda and Angelica. In addition, they are entitled to moral damages in the amount of P50,000.00 each, which is imposed in rape cases without need of showing that the victims suffered mental anguish, fright, serious anxiety and the like.[22]
	GR Nos. 137106-07 2001-01-31	PEOPLE v. JOSE ELPEDES Y SUNAS YNARES-SANTIAGO, J.
The Court notes that the court a quo neither awarded any indemnity ex delicto, which current jurisprudence has fixed at P50,000.00,[44] nor moral damages on account of the rape. It must be stressed in this regard that civil indemnity is separate and distinct from the award of moral damages which is automatically granted in rape cases.[45] Pursuant to controlling case law, the award of P50,000.00 ex delicto is mandatory upon the finding of the fact of rape.[46] Moral damages are additionally awarded without need of pleading or proof of the basis thereof.[47] This is because it is recognized that the victim's injury is concomitant with and necessarily resulting from the odiousness of the crime to warrant per se the award of moral damages.[48]
	GR No. 129769 2001-01-19	PEOPLE v. ANTONIO BELGA YNARES-SANTIAGO, J.
In the case at bar, the trial court has to rely on its own assessment of the credibility of both parties, particularly that of the complainant. Credible witness and credible testimony are the two essential elements for the determination of the weight of a particular testimony. This principle could not ring any truer than in this case where the prosecution relies mainly on the testimony of the complainant, corroborated by the medico-legal findings of a physician.[4] Be that as it may, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and otherwise consistent with human nature.[5]
	GR Nos. 137108-09 2000-11-20	PEOPLE v. JONNIE TAGAYLO Y CORTES DAVIDE JR., C.J.
Anent the civil liability of JONNIE, the trial court merely ordered the payment of civil indemnity in the amount of P50,000 but did not award the payment of moral damages. Thus, in accordance with prevailing jurisprudence, JONNIE should be ordered to pay the amount of P50,000 as moral damages.[24] Moral damages are imposed in rape cases involving young girls between 13 and 19 years of age, taking into account the immeasurable havoc wrought on their youthful feminine psyche. It may be awarded without need of showing that the victim suffered mental anguish, fright, serious anxiety and the like.[25]

PEOPLE v. HENRY DE GUZMAN Y PASCUAL