This case has been cited 6 times or more.
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2014-02-12 |
PEREZ, J. |
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| In reviewing rape cases, the Court is guided by the following principles: (1) to accuse a man of rape is easy, but to disprove the accusation is difficult, though the accused may be innocent; (2) inasmuch as only two persons are usually involved in the crime of rape, the testimony of the complainant should be scrutinized with great caution; and (3) the evidence for the prosecution must stand or fall on its own merit and should not be allowed to draw strength from the weakness of the evidence for the defense.[12] So long as the private complainant's testimony meets the test of credibility, the accused may be convicted on the basis thereof.[13] | |||||
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2011-04-13 |
SERENO, J. |
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| An alibi may be considered with favor only when established by positive, clear and satisfactory evidence. Significantly, where no one corroborates the alibi of an accused, such defense becomes all the weaker for this deficiency. Neither can plain denial, a negative and self-serving evidence stand against the positive identification and categorical testimony made by a victim of rape. A mere denial is seldom given greater evidentiary value than the testimony of a witness who creditably testifies on affirmative matters. All told, the proffered alibi of accused-appellant can not stand against the positive identification by the private complainant that he is the culprit. Basic is the rule that alibi which is easy to concoct can not prevail over the positive identification; what is more, appellant utterly failed to prove that it was physically impossible for him to be at the scene of the crime at the approximate time of its commission. Consequently, accused-appellant's defense of alibi can not prosper. Indeed, the revelation of an innocent child whose chastity was abused deserves full credit, as the willingness of complainant to face police investigation and to undergo the trouble and humiliation of a public trial is eloquent testimony of the truth of her complaint. Stated differently, it is most improbable for a five-year old girl of tender years, so innocent and so guileless as the herein offended party, to brazenly impute a crime so serious as rape to any man if it were not true. [29] | |||||
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2002-04-17 |
BELLOSILLO, J. |
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| The failure of the accused to move for the specification of the date when the alleged crime was committed or for the quashal of the Information on the ground that it does not conform substantially to the prescribed form[10] deprives him of the right to object to evidence which could lawfully be introduced and admitted under an information of more or less general terms but which sufficiently charges the accused with a definite crime.[11] It is indeed too late in the day for the accused to raise this issue because objections to matters of form or substance in the information cannot be made for the first time on appeal. At any rate, it is settled that the exact date of the commission of rape is not an essential element thereof and need not be stated in the information.[12] The Court has sustained the following dates alleged in an information for rape as sufficient for purposes of complying with the provisions of the Rules of Court, to wit: "from November 1990 up to July 21, 1994,"[13] "sometime in November 1995, and some occasions prior and/or subsequent thereto,"[14] "on or about and sometime in the year 1988,"[15] "sometime in the year 1987"[16] and "before and until October 15, 1994."[17] In any event, a review of the evidence presented by the prosecution more than establishes the guilt of the accused for the rape of his daughter. | |||||
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2001-12-14 |
PANGANIBAN, J. |
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| In reviewing rape cases, the Court is guided by the following principles: (1) to accuse a man of rape is easy, but to disprove the accusation is difficult, though the accused may be innocent; (2) inasmuch as only two persons are usually involved in the crime of rape, the testimony of the complainant should be scrutinized with great caution; and (3) the evidence for the prosecution must stand or fall on its own merit and should not be allowed to draw strength from the weakness of the evidence for the defense. Corollary to the foregoing legal yardsticks is the dictum that when a victim of rape says that she has been defiled, she says in effect all that is necessary to show that rape has been committed against her. So long as her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[15] | |||||
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2001-12-11 |
PER CURIAM |
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| All told, the proffered alibi of accused-appellant cannot stand against the positive identification by the complainant that he is the defiler of her womanhood. Indeed, the revelation of an innocent girl not even into her teens whose chastity has been abused deserves full credit, as the willingness of complainant to face police investigation and to undergo the trouble and humiliation of a public trial is eloquent testimony of the truth of her complaint.[27] In short, it is most improbable for an innocent and guileless girl of seven years as herein offended party, to brazenly impute a crime so serious as rape to any man, let alone her uncle, if it were not true.[28] | |||||
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2001-07-31 |
MENDOZA, J. |
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| A duly certified certificate of live birth showing complainant's age, or some other official document on record, such as a school record, has been recognized as competent evidence.[69] | |||||