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GR No. 182550

2011-03-23

BRION, J.

We agree with the CA that while AAA's testimony had inconsistencies, these inconsistencies do not at all affect her credibility. Inconsistencies are to be expected when a person is recounting a traumatic experience.[15] Rape, a traumatic experience, is usually not remembered in detail.[16] This observation is more pronounced in the case of minors such as AAA who was merely ten years old at the time she testified. For this reason, we held in People of the Philippines v. Domingo Sta. Ana y Tupig that it is not proper to judge the actions of children who have undergone traumatic experience by norms of behavior expected from adults.[17]

GR No. 185206

2010-08-25

PEOPLE v. MANUEL AGUILAR

PEREZ, J.

The Court rebuffed accused-appellant's defense of denial. Aside from being weak, it is merely negative and self-serving evidence which pales in comparison to XYZ's and AAA's clear narration of facts and positive identification of the appellant. The testimony of XYZ, coupled with the medical findings of Dr. Muñoz, is enough to confirm the truthfulness of the charge. Deeply entrenched in jurisprudence is the rule that findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[18]

GR No. 177219

2010-07-09

PEOPLE v. ROGELIO ALARCON

MENDOZA, J.

As the Court of Appeals decided not to disturb the findings of the trial court with respect to her credibility, the Court finds no reason to do otherwise. It has consistently held that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance that would have affected the result of the case.[32]

GR No. 188106

2009-11-25

PEOPLE v. ANTONIO DALISAY Y DESTRESA

NACHURA, J.

This eloquent testimony of the victim, coupled with the medical findings attesting to her non-virgin state, should be enough to confirm the truth of her charges.[19] Further, deeply entrenched in our jurisprudence is the rule that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[20]

GR No. 187531

2009-10-16

PEOPLE v. ELMER PERALTA Y HIDALGO

NACHURA, J.

In the instant case, the victim testified that she was raped and identified the appellant as the one who maligned her. Her narration was further supported by medical findings, coupled by the testimony of the examining physician, with regard to her non-virgin state. Of note moreover is that the trial court, which had the undisputed vantage in the evaluation and appreciation of testimonial evidence, found the victim's narration of her painful ordeal as clear, categorical, straightforward, sincere, and truthful.[15] Well-entrenched in our jurisprudence is the rule that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance that would have affected the result of the case.[16]

GR No. 177565

2008-01-28

PEOPLE v. ELMER GLIVANO y SILVALLANA

NACHURA, J.

Furthermore, the general rule is that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[23] The stringency with which appellate tribunals have observed this rule is predicated on the undisputed vantage of the trial court in the evaluation and appreciation of testimonial evidence.[24]

GR NO. 170191

2006-08-16

PEOPLE v. RODOLFO SUYU

CALLEJO, SR., J.

We are not persuaded. To begin with, the rule is that, in the absence of any clear showing that the trial court overlooked, misunderstood, or misapplied facts or circumstances of weight and substance, which would have affected the result of the case, the findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal.[54] The stringency with which appellate tribunals have observed this rule is predicated on the undisputed vantage of the trial court in the evaluation and appreciation of testimonial evidence.[55]

GR No. 146803

2004-01-14

PEOPLE v. CLEMENTINO LOU Y GALINDO

VITUG, J.

Appellant argues that the victim's getting married soon after her supposed horrendous ordeal is uncharacteristic of a rape victim. Appellant apparently fits the fact of her marriage into his own desperate mold of defense. He fails to consider the fact that different people react differently to given situations and that there is no known standard form of human behavioral response when confronted particularly with a frightful experience.[18] In any case, her subsequent marriage is of no moment; indeed, it could have even strengthened her determination to pursue her complaint to its just conclusion.

GR Nos. 148743-45

2003-11-18

PEOPLE v. FELIX MONTES Y NALLOS

PANGANIBAN, J.

Moreover, it is not proper to judge by adult norms of behavior the actions of children who have undergone traumatic experiences.[20] Certainly, a child cannot be expected to act like an adult or do what may be expected of mature people under similar circumstances.[21]

GR Nos. 132482-83

2001-02-20

PEOPLE v. ELISEO TIO Y TORCUATO

BELLOSILLO, J.

Be that as it may, ballistics expert Ireneo Ordiano of the NBI was careful to say that he does not know actually whether the caliber 45 slug was actually recovered from the crime scene x x x All he can say was that it was submitted to him for ballistics examination to determine whether it was fired from the 45 caliber pistol.[5] The allegation by accused-appellant that Gundre Eckman failed to surrender the murder weapon immediately after the incident to tamper with vital evidence and cover up the tracks of his cousin Richard Acop is specious. It is a futile and pathetic effort on the part of accused-appellant to mislead and emasculate the damning prosecution evidence. In contrast, we discern no falsity in Gundre Eckman's explanation that he took the murder weapon home for no other reason than to ensure the integrity of a vital evidence. Granting that Eckman's behavior was irrational in view of the proximity of the police station to his residence, we are not disposed to ascribe ill motive on his part for different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response where one is confronted with a strange or frightful experience.[6]

GR No. 136254

2000-12-04

PEOPLE v. REYNALDO DAGPIN Y PAUSAL

BELLOSILLO, J.

The delay and initial reluctance of a rape victim to make public the assault on her virtue is neither unknown nor uncommon.[12] Such delay and initial reluctance do not impair her credibility when satisfactorily explained.[13] A plausible reason to incur delay is the death threat from the accused[14] and in many instances, rape victims simply suffer in silence.[15] Ellen's lips were sealed for almost two (2) months due to accused-appellant's death threats. We find such circumstance an adequate reason for her delay in revealing her misfortune.

GR Nos. 127750-52

2000-11-20

PEOPLE v. CRISANTO DIGMA Y UBAY

BELLOSILLO, J.

Finally, accused-appellant faults Adora for waiting to break her silence until they were seen by Nora. No, we rule that Adora is blameless. Delay in reporting rape does not by itself undermine the charge when it is grounded on death threats from the accused.[32] Adora was raised in the province, inexperienced in worldly ways, and whose actuations under such immensely arduous and trying situations were dominated more by fear rather than by reason. She could not have been expected to have the courage to disregard the threats to her family.

GR Nos. 121651-52

2000-08-16

PEOPLE v. FERNANDO WATIMAR

YNARES-SANTIAGO, J.

[10]10 People v. Emil Babera y Rabanera, G.R. No. 130609, 30 May 2000, p. 8, citing People v. Dacoba, 289 SCRA 265 [1998] and People v. Gagto, 253 SCRA 455 [1996].10

	GR No. 182550 2011-03-23	PEOPLE v. RUEL VELARDE BRION, J.
We agree with the CA that while AAA's testimony had inconsistencies, these inconsistencies do not at all affect her credibility. Inconsistencies are to be expected when a person is recounting a traumatic experience.[15] Rape, a traumatic experience, is usually not remembered in detail.[16] This observation is more pronounced in the case of minors such as AAA who was merely ten years old at the time she testified. For this reason, we held in People of the Philippines v. Domingo Sta. Ana y Tupig that it is not proper to judge the actions of children who have undergone traumatic experience by norms of behavior expected from adults.[17]
	GR No. 185206 2010-08-25	PEOPLE v. MANUEL AGUILAR PEREZ, J.
The Court rebuffed accused-appellant's defense of denial. Aside from being weak, it is merely negative and self-serving evidence which pales in comparison to XYZ's and AAA's clear narration of facts and positive identification of the appellant. The testimony of XYZ, coupled with the medical findings of Dr. Muñoz, is enough to confirm the truthfulness of the charge. Deeply entrenched in jurisprudence is the rule that findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[18]
	GR No. 177219 2010-07-09	PEOPLE v. ROGELIO ALARCON MENDOZA, J.
As the Court of Appeals decided not to disturb the findings of the trial court with respect to her credibility, the Court finds no reason to do otherwise. It has consistently held that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance that would have affected the result of the case.[32]
	GR No. 188106 2009-11-25	PEOPLE v. ANTONIO DALISAY Y DESTRESA NACHURA, J.
This eloquent testimony of the victim, coupled with the medical findings attesting to her non-virgin state, should be enough to confirm the truth of her charges.[19] Further, deeply entrenched in our jurisprudence is the rule that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[20]
	GR No. 187531 2009-10-16	PEOPLE v. ELMER PERALTA Y HIDALGO NACHURA, J.
In the instant case, the victim testified that she was raped and identified the appellant as the one who maligned her. Her narration was further supported by medical findings, coupled by the testimony of the examining physician, with regard to her non-virgin state. Of note moreover is that the trial court, which had the undisputed vantage in the evaluation and appreciation of testimonial evidence, found the victim's narration of her painful ordeal as clear, categorical, straightforward, sincere, and truthful.[15] Well-entrenched in our jurisprudence is the rule that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance that would have affected the result of the case.[16]
	GR No. 177565 2008-01-28	PEOPLE v. ELMER GLIVANO y SILVALLANA NACHURA, J.
Furthermore, the general rule is that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and are not to be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied facts or circumstances of weight and substance which would have affected the result of the case.[23] The stringency with which appellate tribunals have observed this rule is predicated on the undisputed vantage of the trial court in the evaluation and appreciation of testimonial evidence.[24]
	GR NO. 170191 2006-08-16	PEOPLE v. RODOLFO SUYU CALLEJO, SR., J.
We are not persuaded. To begin with, the rule is that, in the absence of any clear showing that the trial court overlooked, misunderstood, or misapplied facts or circumstances of weight and substance, which would have affected the result of the case, the findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal.[54] The stringency with which appellate tribunals have observed this rule is predicated on the undisputed vantage of the trial court in the evaluation and appreciation of testimonial evidence.[55]
	GR No. 146803 2004-01-14	PEOPLE v. CLEMENTINO LOU Y GALINDO VITUG, J.
Appellant argues that the victim's getting married soon after her supposed horrendous ordeal is uncharacteristic of a rape victim. Appellant apparently fits the fact of her marriage into his own desperate mold of defense. He fails to consider the fact that different people react differently to given situations and that there is no known standard form of human behavioral response when confronted particularly with a frightful experience.[18] In any case, her subsequent marriage is of no moment; indeed, it could have even strengthened her determination to pursue her complaint to its just conclusion.
	GR Nos. 148743-45 2003-11-18	PEOPLE v. FELIX MONTES Y NALLOS PANGANIBAN, J.
Moreover, it is not proper to judge by adult norms of behavior the actions of children who have undergone traumatic experiences.[20] Certainly, a child cannot be expected to act like an adult or do what may be expected of mature people under similar circumstances.[21]
	GR Nos. 132482-83 2001-02-20	PEOPLE v. ELISEO TIO Y TORCUATO BELLOSILLO, J.
Be that as it may, ballistics expert Ireneo Ordiano of the NBI was careful to say that he does not know actually whether the caliber 45 slug was actually recovered from the crime scene x x x All he can say was that it was submitted to him for ballistics examination to determine whether it was fired from the 45 caliber pistol.[5] The allegation by accused-appellant that Gundre Eckman failed to surrender the murder weapon immediately after the incident to tamper with vital evidence and cover up the tracks of his cousin Richard Acop is specious. It is a futile and pathetic effort on the part of accused-appellant to mislead and emasculate the damning prosecution evidence. In contrast, we discern no falsity in Gundre Eckman's explanation that he took the murder weapon home for no other reason than to ensure the integrity of a vital evidence. Granting that Eckman's behavior was irrational in view of the proximity of the police station to his residence, we are not disposed to ascribe ill motive on his part for different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response where one is confronted with a strange or frightful experience.[6]
	GR No. 136254 2000-12-04	PEOPLE v. REYNALDO DAGPIN Y PAUSAL BELLOSILLO, J.
The delay and initial reluctance of a rape victim to make public the assault on her virtue is neither unknown nor uncommon.[12] Such delay and initial reluctance do not impair her credibility when satisfactorily explained.[13] A plausible reason to incur delay is the death threat from the accused[14] and in many instances, rape victims simply suffer in silence.[15] Ellen's lips were sealed for almost two (2) months due to accused-appellant's death threats. We find such circumstance an adequate reason for her delay in revealing her misfortune.
	GR Nos. 127750-52 2000-11-20	PEOPLE v. CRISANTO DIGMA Y UBAY BELLOSILLO, J.
Finally, accused-appellant faults Adora for waiting to break her silence until they were seen by Nora. No, we rule that Adora is blameless. Delay in reporting rape does not by itself undermine the charge when it is grounded on death threats from the accused.[32] Adora was raised in the province, inexperienced in worldly ways, and whose actuations under such immensely arduous and trying situations were dominated more by fear rather than by reason. She could not have been expected to have the courage to disregard the threats to her family.
	GR Nos. 121651-52 2000-08-16	PEOPLE v. FERNANDO WATIMAR YNARES-SANTIAGO, J.
[10]10 People v. Emil Babera y Rabanera, G.R. No. 130609, 30 May 2000, p. 8, citing People v. Dacoba, 289 SCRA 265 [1998] and People v. Gagto, 253 SCRA 455 [1996].10

PEOPLE v. DOMINGO STA. ANA Y TUPIG