Lawyerly

GR No. 186119

2009-10-27

CHICO-NAZARIO, J.

To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[41] A denial unsubstantiated by clear and convincing evidence is negative, self-serving, merits no weight in law, and cannot therefore be given greater evidentiary value than the testimonies of credible witnesses who testify on affirmative matters.[42] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[43] Indeed, denial cannot prevail over the positive testimonies of prosecution witnesses who were not shown to have any ill motive to testify against accused-appellant. Absence of improper motives makes a testimony worthy of full faith and credence.[44] In this case, there being no strong and credible evidence adduced to overcome the testimonies of Doris Labini and Tomasito de los Santos pointing to accused-appellant as the culprit, no weight can be given to his denial.

GR No. 186379

2009-08-19

PEOPLE v. BIENVENIDO LAZARO

CHICO-NAZARIO, J.

Medical findings revealed that the victim's vagina had old lacerations that were consistent with her claim that she was molested. Against the damning evidence adduced by the prosecution, what appellant could only muster is a barefaced denial. Unfortunately for him, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence, which deserves no weight in law and cannot be given greater evidentiary value over the testimonies of credible witnesses who testify on affirmative matters.[24] Between the self-serving testimony of Bienvenido and the positive declaration of the victim, the latter deserves greater credence.[25]

GR No. 180380

2009-08-04

RAYMUND MADALI v. PEOPLE

CHICO-NAZARIO, J.

Against the damning evidence adduced by the prosecution, petitioners Raymund and Rodel could only muster mere denial. Unfortunately for them, their defense was much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence that deserves no weight in law. It cannot be given greater evidentiary value than the testimony of a credible witness who testifies on affirmative matters.[14] Between the self-serving testimonies of petitioners and the positive identification by the eyewitness, the latter deserves greater credence.[15]

GR No. 185841

2009-08-04

PEOPLE v. ISMAEL DIAZ

CHICO-NAZARIO, J.

To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[56] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[57] In the instant case, appellants failed to adduce strong and credible evidence to overcome the testimonies of the prosecution's eyewitnesses. The testimonies of the defense witnesses (Josue de Vera, Imelda Quinto and Ricardo Avelino), who alleged that appellants were with them and were not holding firearms when the victims were gunned down, were not given credence by both the trial court and the Court of Appeals. These witnesses were not credible witnesses. Thus, denial, unsubstantiated by any credible evidence, deserves no weight in law.

GR No. 184598

2009-06-23

PEOPLE v. JULIO MANALILI

CHICO-NAZARIO, J.

In contrast to damning evidence adduced by the prosecution, Julio gave nothing but alibi and denial. Unfortunately for Julio, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Julio gave only self-serving testimonies, coroborated only by the testimonies of his wife and friends. As we have held, "[a]libi becomes less plausible when it is corroborated by relatives and friends who may then not be impartial witnesses."[30] IN the same vein, denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence, which deserves no weight in law and cannot be given greater evidentiary value over the testimonies of credible witnesses who testify on affirmative matters.[31] Alibi and denial are an inherently weak defense and must be rejected when the accused's identity is satisfactorily and a categorically established by the eyewitnesses to the offense, especially when such eyewitnesses have no ill motive to testify falsely.[32] In the case at bar, the defense failed to show that AAA was motivated by ill will.

GR No. 172744

2008-09-29

MARVIN ANGELES v. PEOPLE

TINGA, J.

The Court agrees with the observation of the Court of Appeals that there is no showing that the RTC was arbitrary in its findings of fact and appreciation of evidence, neither did it overlook nor ignore any substantial facts.[16] It is a well-settled rule that the evaluation of the testimonies of witnesses by the trial court is received on appeal with the highest respect because such court has the direct opportunity to observe the witnesses on the stand and determine if they are telling the truth or not.[17] We see no reason to deviate from this rule.

GR No. 178545

2008-09-29

PEOPLE v. LEO BARRIGA

TINGA, J.

It is a well-settled rule that the evaluation of the testimonies of witnesses by the trial court is received on appeal with the highest respect because such court has the direct opportunity to observe the witnesses on the stand and determine if they are telling the truth or not.[46] We see no reason to deviate from this rule.

GR No. 172470

2008-04-08

PEOPLE v. SAMMY RAMOS Y DALERE

CHICO-NAZARIO, J.

From the foregoing, the prosecution adequately established in graphic detail that during the incidents in question, AAA stayed with the appellant in the barracks of the 642 Construction in Cogon, Gubat, Sorsogon and that appellant ravished his 13-year old daughter in four different dates, i.e., in the early morning of 18 January 1992, during the nights of 19 January 1992, 20 January 1992 and 28 March 1992. In all these deflorations, the victim resisted the bestial acts of the appellant, but the same proved fruitless as the latter was far stronger than her. Medical findings revealed that the victim's hymen had old lacerations at various areas and that her labia minora had abrasion which are consistent with her claim that she was molested. Against the damning evidence adduced by the prosecution, what appellant could only muster is a barefaced denial. Unfortunately for the appellant, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence which deserves no weight in law and cannot be given greater evidentiary value over the testimony of credible witnesses who testify on affirmative matters.[41] Between the self-serving testimony of appellant and the positive identification by the eyewitness, the latter deserves greater credence.[42]

GR NO. 166479

2006-02-28

RODOLFO C. VELASCO v. PEOPLE

CHICO-NAZARIO, J.

To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[27] Settled is the rule that the defense of alibi is inherently weak and crumbles in the light of positive declarations of truthful witnesses who testified on affirmative matters.[28] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[29] There being no strong and credible evidence adduced to overcome the testimonies of private complainant and Armando Maramba pointing to him as the culprit, no weight can be given petitioner's denial.

GR No. 148730

2003-06-26

PEOPLE v. JOSE DELA CRUZ Y DACILLO

BELLOSILLO, J.

Robo con homicidio is an indivisible offense, a special complex crime. It carries a severe penalty because the law sees in this crime that men place lucre above the value of human life, thus justifying the imposition of a harsher penalty than that for simple robbery or homicide.[13] A conviction for robbery with homicide requires the prosecution to firmly establish the following elements: (a) the taking of personal property with violence or intimidation against persons; (b) the property taken belongs to another; (c) the taking was done with animo lucrandi; and, (d) on the occasion of the robbery or by reason thereof, homicide was committed.[14]

GR Nos. 127750-52

2000-11-20

PEOPLE v. CRISANTO DIGMA Y UBAY

BELLOSILLO, J.

In rape cases, the evaluation of the credibility of witnesses is addressed to the sound discretion of the trial judge whose conclusion thereon deserves much weight and respect[14] because the judge had the direct opportunity to observe them on the stand and ascertain if they were telling the truth or not.[15] Trial courts assess the credibility of witnesses on two (2) aspects: demeanor of witnesses as they deliver their testimonies and contents of their testimonies. As to the first, appellate courts generally yield to the trial court's conclusion because, as aforementioned, it had the advantage of observing first hand the witnesses' deportment on the stand then assess their performance accordingly. As to the second, appellate courts make their own independent evaluation, based on the transcript of stenographic notes, to be tested against human nature and ordinary habits of life and to be scrutinized for consistency, among other criteria. The result of the evaluation may render illusory the trial court's conclusion on the first aspect or it may not. Having discharged such duty, no reason compels us to substitute a finding different from that of the trial court. The qualities of being categorical, candid and spontaneous are discernible from each and every page of the transcript of stenographic notes containing Adora's testimonies both on direct and cross examinations. We note that she was subjected to rigid and lengthy cross examination on the same day her direct examination was concluded. She remained unshaken.[16]

	GR No. 186119 2009-10-27	PEOPLE v. PABLO LUSABIO CHICO-NAZARIO, J.
To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[41] A denial unsubstantiated by clear and convincing evidence is negative, self-serving, merits no weight in law, and cannot therefore be given greater evidentiary value than the testimonies of credible witnesses who testify on affirmative matters.[42] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[43] Indeed, denial cannot prevail over the positive testimonies of prosecution witnesses who were not shown to have any ill motive to testify against accused-appellant. Absence of improper motives makes a testimony worthy of full faith and credence.[44] In this case, there being no strong and credible evidence adduced to overcome the testimonies of Doris Labini and Tomasito de los Santos pointing to accused-appellant as the culprit, no weight can be given to his denial.
	GR No. 186379 2009-08-19	PEOPLE v. BIENVENIDO LAZARO CHICO-NAZARIO, J.
Medical findings revealed that the victim's vagina had old lacerations that were consistent with her claim that she was molested. Against the damning evidence adduced by the prosecution, what appellant could only muster is a barefaced denial. Unfortunately for him, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence, which deserves no weight in law and cannot be given greater evidentiary value over the testimonies of credible witnesses who testify on affirmative matters.[24] Between the self-serving testimony of Bienvenido and the positive declaration of the victim, the latter deserves greater credence.[25]
	GR No. 180380 2009-08-04	RAYMUND MADALI v. PEOPLE CHICO-NAZARIO, J.
Against the damning evidence adduced by the prosecution, petitioners Raymund and Rodel could only muster mere denial. Unfortunately for them, their defense was much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence that deserves no weight in law. It cannot be given greater evidentiary value than the testimony of a credible witness who testifies on affirmative matters.[14] Between the self-serving testimonies of petitioners and the positive identification by the eyewitness, the latter deserves greater credence.[15]
	GR No. 185841 2009-08-04	PEOPLE v. ISMAEL DIAZ CHICO-NAZARIO, J.
To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[56] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[57] In the instant case, appellants failed to adduce strong and credible evidence to overcome the testimonies of the prosecution's eyewitnesses. The testimonies of the defense witnesses (Josue de Vera, Imelda Quinto and Ricardo Avelino), who alleged that appellants were with them and were not holding firearms when the victims were gunned down, were not given credence by both the trial court and the Court of Appeals. These witnesses were not credible witnesses. Thus, denial, unsubstantiated by any credible evidence, deserves no weight in law.
	GR No. 184598 2009-06-23	PEOPLE v. JULIO MANALILI CHICO-NAZARIO, J.
In contrast to damning evidence adduced by the prosecution, Julio gave nothing but alibi and denial. Unfortunately for Julio, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Julio gave only self-serving testimonies, coroborated only by the testimonies of his wife and friends. As we have held, "[a]libi becomes less plausible when it is corroborated by relatives and friends who may then not be impartial witnesses."[30] IN the same vein, denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence, which deserves no weight in law and cannot be given greater evidentiary value over the testimonies of credible witnesses who testify on affirmative matters.[31] Alibi and denial are an inherently weak defense and must be rejected when the accused's identity is satisfactorily and a categorically established by the eyewitnesses to the offense, especially when such eyewitnesses have no ill motive to testify falsely.[32] In the case at bar, the defense failed to show that AAA was motivated by ill will.
	GR No. 172744 2008-09-29	MARVIN ANGELES v. PEOPLE TINGA, J.
The Court agrees with the observation of the Court of Appeals that there is no showing that the RTC was arbitrary in its findings of fact and appreciation of evidence, neither did it overlook nor ignore any substantial facts.[16] It is a well-settled rule that the evaluation of the testimonies of witnesses by the trial court is received on appeal with the highest respect because such court has the direct opportunity to observe the witnesses on the stand and determine if they are telling the truth or not.[17] We see no reason to deviate from this rule.
	GR No. 178545 2008-09-29	PEOPLE v. LEO BARRIGA TINGA, J.
It is a well-settled rule that the evaluation of the testimonies of witnesses by the trial court is received on appeal with the highest respect because such court has the direct opportunity to observe the witnesses on the stand and determine if they are telling the truth or not.[46] We see no reason to deviate from this rule.
	GR No. 172470 2008-04-08	PEOPLE v. SAMMY RAMOS Y DALERE CHICO-NAZARIO, J.
From the foregoing, the prosecution adequately established in graphic detail that during the incidents in question, AAA stayed with the appellant in the barracks of the 642 Construction in Cogon, Gubat, Sorsogon and that appellant ravished his 13-year old daughter in four different dates, i.e., in the early morning of 18 January 1992, during the nights of 19 January 1992, 20 January 1992 and 28 March 1992. In all these deflorations, the victim resisted the bestial acts of the appellant, but the same proved fruitless as the latter was far stronger than her. Medical findings revealed that the victim's hymen had old lacerations at various areas and that her labia minora had abrasion which are consistent with her claim that she was molested. Against the damning evidence adduced by the prosecution, what appellant could only muster is a barefaced denial. Unfortunately for the appellant, his defense is much too flaccid to stay firm against the weighty evidence for the prosecution. Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence which deserves no weight in law and cannot be given greater evidentiary value over the testimony of credible witnesses who testify on affirmative matters.[41] Between the self-serving testimony of appellant and the positive identification by the eyewitness, the latter deserves greater credence.[42]
	GR NO. 166479 2006-02-28	RODOLFO C. VELASCO v. PEOPLE CHICO-NAZARIO, J.
To be believed, denial must be buttressed by strong evidence of non-culpability. Otherwise, it is purely self-serving and without merit.[27] Settled is the rule that the defense of alibi is inherently weak and crumbles in the light of positive declarations of truthful witnesses who testified on affirmative matters.[28] Greater weight is given to the categorical identification of the accused by the prosecution witnesses than to the accused's plain denial of participation in the commission of the crime.[29] There being no strong and credible evidence adduced to overcome the testimonies of private complainant and Armando Maramba pointing to him as the culprit, no weight can be given petitioner's denial.
	GR No. 148730 2003-06-26	PEOPLE v. JOSE DELA CRUZ Y DACILLO BELLOSILLO, J.
Robo con homicidio is an indivisible offense, a special complex crime. It carries a severe penalty because the law sees in this crime that men place lucre above the value of human life, thus justifying the imposition of a harsher penalty than that for simple robbery or homicide.[13] A conviction for robbery with homicide requires the prosecution to firmly establish the following elements: (a) the taking of personal property with violence or intimidation against persons; (b) the property taken belongs to another; (c) the taking was done with animo lucrandi; and, (d) on the occasion of the robbery or by reason thereof, homicide was committed.[14]
	GR Nos. 127750-52 2000-11-20	PEOPLE v. CRISANTO DIGMA Y UBAY BELLOSILLO, J.
In rape cases, the evaluation of the credibility of witnesses is addressed to the sound discretion of the trial judge whose conclusion thereon deserves much weight and respect[14] because the judge had the direct opportunity to observe them on the stand and ascertain if they were telling the truth or not.[15] Trial courts assess the credibility of witnesses on two (2) aspects: demeanor of witnesses as they deliver their testimonies and contents of their testimonies. As to the first, appellate courts generally yield to the trial court's conclusion because, as aforementioned, it had the advantage of observing first hand the witnesses' deportment on the stand then assess their performance accordingly. As to the second, appellate courts make their own independent evaluation, based on the transcript of stenographic notes, to be tested against human nature and ordinary habits of life and to be scrutinized for consistency, among other criteria. The result of the evaluation may render illusory the trial court's conclusion on the first aspect or it may not. Having discharged such duty, no reason compels us to substitute a finding different from that of the trial court. The qualities of being categorical, candid and spontaneous are discernible from each and every page of the transcript of stenographic notes containing Adora's testimonies both on direct and cross examinations. We note that she was subjected to rigid and lengthy cross examination on the same day her direct examination was concluded. She remained unshaken.[16]

PEOPLE v. DOMINGO BACCAY