This case has been cited 4 times or more.
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2003-07-17 |
CORONA, J. |
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| Evidence in criminal cases is not limited to the declarations made in open court; it includes all documents, affidavits or sworn statements of the witnesses, and other supporting evidence. It comprehends something more than just the mere testimony of a witness.[14] Thus, when a sworn statement has been formally offered as evidence, it forms an integral part of the prosecution evidence which should not be ignored for it complements and completes the testimony on the witness stand. A sworn statement is a written declaration of facts to which the declarant has sworn before an officer authorized to administer oaths. This oath vests credibility and trustworthiness on the document. The fact that a witness fails to reiterate, during trial, the contents of his sworn statement should not affect his credibility and render the sworn statement useless and insignificant, as long as it is presented as evidence in open court. This is not to say, however, that the sworn statement should be given more probative value than the actual testimony. Rather, the sworn statement and the open court declarations must be evaluated and examined together in toto so that a full and thorough determination of the merits of the case may be achieved. Giving weight to a witness' oral testimony during the trial should not mean being oblivious to the other pieces of available evidence such as the sworn statement. In like manner, the court cannot give probative value to the sworn statement to the exclusion of the oral testimony. In every case, the court should review, assess and weigh the totality of the evidence presented by the parties. It should not confine itself to oral testimony during trial. In the instant case, the sworn statement of complainant contained a detailed account of the two rape incidents which made it as convincing and as persuasive as her testimony. | |||||
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2002-02-15 |
QUISUMBING, J. |
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| Coming now to the second assigned error, in regard to Criminal Case No. 97-9946, we agree with appellants that the records are bereft of evidence that could show that appellant Mario Castillo had carnal knowledge of complainant. Even admitting that Mario stroked and sucked her breasts, the records do not show that Mario forced, or attempted to force, his manhood on Chanet. Conviction of appellants could not be based on the alleged implication of intercourse to be gleaned from the over-all testimony of the victim. For conviction of the crime of rape to stand, there must be clear and convincing evidence to prove the allegation that the person charged had carnal knowledge of complainant against her will.[53] | |||||
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2002-02-15 |
QUISUMBING, J. |
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| A rape charge is a serious matter with pernicious consequences both for the appellant and the complainant,[18] hence utmost care must be taken in the review of a decision involving conviction for rape. In this case, however, a careful perusal of the records shows no cause to disturb the lower court's findings. | |||||
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2000-02-01 |
YNARES-SANTIAGO, J. |
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| To restate what had been said earlier, it is highly inconceivable vis-a-vis the prevailing facts of the case for the victim to conjure a tale of ravishment and, in the process, subject herself and her family to the disgrace, social humiliation and trauma attendant to a prosecution for rape as well as the stigma of a lifetime of shame incident thereto.[34] Furthermore, the conduct of the victim immediately following the alleged assault is of utmost important so as to establish the truth or falsity of the charges of rape.[35] In this case, we find the private complainant's prompt report of her defilement to her husband as well as the authorities as convincing indications that she has been truly wronged. A complainant's act in immediately reporting the commission, of rape has been considered by this Court as a factor strengthening her credibility.[36] | |||||