This case has been cited 24 times or more.
|
2014-01-27 |
DEL CASTILLO, J. |
||||
| Like the lower courts, we find the narration of "AAA" to be candid, frank and straightforward. There is nothing therein that appears to be unnatural or illogical. Moreover, "AAA's" claim of rape is supported by the medical findings of Dr. Perez, another prosecution witness. "Where a victim's testimony is corroborated by the physical findings of penetration, there is sufficient basis for concluding that sexual intercourse did take place. A rape victim's account is sufficient to support a conviction for rape if it is straightforward, candid and corroborated by the medical findings of the examining physician, as in the present case."[13] | |||||
|
2014-01-27 |
DEL CASTILLO, J. |
||||
| The defenses of denial and alibi proffered by appellant were correctly rejected by the courts below in view of "AAA's" positive testimony and unflawed identification of appellant as the culprit. Alibi and denial are inherently weak defenses and "must be brushed aside when the prosecution has sufficiently and positively ascertained the identity of the accused."[20] And as often stressed, positive testimony prevails over negative testimony.[21] Also, for his defense of alibi to prosper, appellant must prove not only that he was somewhere else when the crime was committed but he must also satisfactorily establish that it was physically impossible for him to be at the crime scene at the time of its commission. Appellant miserably failed in this regard. | |||||
|
2013-06-05 |
LEONARDO-DE CASTRO, J. |
||||
| Jurisprudence teaches that testimonies of child victims are given full weight and credit, for when a woman or a girl-child says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed. Youth and immaturity are generally badges of truth and sincerity.[25] Moreover, we held in People v. Oden[26] that "the spontaneity with which the victim has detailed the incidents of rape, the tears she ha[d] shed at the stand while recounting her experience, and her consistency almost throughout her account dispel any insinuation of a rehearsed testimony." | |||||
|
2012-03-21 |
LEONARDO-DE CASTRO, J. |
||||
| In the instant case, the Court finds trustworthy the straightforward testimony of AAA that it was the accused-appellant who forcibly had carnal knowledge of her on that fateful afternoon of February 14, 1995. AAA detailed with sufficient clarity how she was sexually abused by the accused- appellant. We keep in mind the well-entrenched doctrine that the testimonies of child victims are given full weight and credit, for when a woman or a girl-child says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed. Youth and immaturity are generally badges of truth and sincerity.[50] The testimony of AAA was further bolstered by the medical findings of Dr. Plaza who attested to the presence of "deep, hymenal notches at 3 o'clock and 9 o'clock positions" in AAA's organ, which led the physician to conclude that it was indeed possible that AAA was sexually abused. BBB, the younger sister of AAA, likewise pointed to the accused-appellant as the perpetrator of the dastardly act against AAA.[51] | |||||
|
2011-10-19 |
BERSAMIN, J. |
||||
| That AAA's recollection on the rape was corroborated by the results of the medico-legal examination was sufficient proof of the consummation of rape. We have ruled that rape can be established by the sole testimony of the victim that is credible and untainted with serious uncertainty.[26] With more reason is this true when the medical findings supported the testimony of the victim,[27] like herein. | |||||
|
2011-03-16 |
PEREZ, J. |
||||
| The straightforward and consistent answers to the questions, which were phrased and re-phrased in order to test that AAA well understood the information elicited from her, said it all - she had been raped. When a woman, more so a minor, says so, she says in effect all that is essential to show that rape was committed.[104] Significantly, youth and immaturity are normally badges of truth and honesty.[105] | |||||
|
2010-09-15 |
PEREZ, J. |
||||
| The result of AAA's medical examination corroborated her testimony of defilement. The medical findings of Dr. Vasquez revealed two healed hymenal lacerations on AAA's private part, which findings are consistent with AAA's testimony that appellant twice inserted his penis into her vagina. Where a victim's testimony is corroborated by the physical findings of penetration, there is sufficient basis for concluding that sexual intercourse did take place.[30] | |||||
|
2010-08-25 |
PEREZ, J. |
||||
| Testimonies of child victims are given full weight and credit, for when a woman or a girl-child says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed. Youth and maturity are generally badges of truth and sincerity.[17] | |||||
|
2010-07-05 |
VELASCO JR., J. |
||||
| By the distinctive nature of rape cases, conviction thereon usually rests solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing and consistent with human nature and the normal course of things.[8] Accordingly, the Court has consistently adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[9] | |||||
|
2010-06-29 |
VELASCO JR., J. |
||||
| Rape is essentially an offense of secrecy involving only two persons and not generally attempted save in secluded places far from prying eyes. By the intrinsic nature of rape cases, the crime usually commences solely upon the word of the offended girl herself and conviction invariably turns upon her credibility, as the People's single witness of the actual occurrence. [12] Accordingly, certain guiding principles have been formulated in resolving rape cases. Foremost of these: an offended woman's testimony hurdling the exacting test of credibility would suffice to convict.[13] In fine, the credibility of the victim is always the single most important issue in prosecution for rape.[14] Withal, in passing upon the credibility of the victim-witness, the highest degree of respect must be afforded to the evaluation and findings of the trial court.[15] | |||||
|
2010-02-01 |
DEL CASTILLO, J. |
||||
| The twin defenses of denial and alibi raised by petitioners must necessarily fail in view of the positive identification made by the prosecution witnesses. Alibi and denial are inherently weak defenses and must be brushed aside when the prosecution has sufficiently and positively ascertained the identity of the accused.[27] And it is only axiomatic that positive testimony prevails over negative testimony.[28] | |||||
|
2010-01-21 |
LEONARDO-DE CASTRO, J. |
||||
| There are three settled principles in reviewing evidence on rape cases: (1) an accusation for rape can be made with facility, it is difficult to prove but more difficult for the accused, though innocent, to disprove; (2) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[18] | |||||
|
2009-12-23 |
VELASCO JR., J. |
||||
| By the distinctive nature of rape cases, conviction usually rests solely on the basis of the victim's testimony, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things.[15] Accordingly, the Court has unfailingly adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits, and cannot be allowed to draw strength from the weakness of the evidence for the defense. [16] | |||||
|
2009-11-25 |
CHICO-NAZARIO, J. |
||||
| The twin defenses of denial and alibi raised by accused-appellant must fail in light of the positive identification made by one of his victims, Jay. Alibi and denial are inherently weak defenses and must be brushed aside when the prosecution has sufficiently and positively ascertained the identity of the accused.[20] It is only axiomatic that positive testimony prevails over negative testimony.[21] Accused-appellant and his two victims reside in the same barangay and are therefore familiar with one another. Thus, Jay could not have been mistaken on accused-appellant's identity. For alibi to prosper, it must be established by positive, clear and satisfactory proof that it was physically impossible for the accused to have been at the scene of the crime at the time of its commission, and not merely that accused was somewhere else.[22] Accused-appellant's alibi that he was at his sister's house at the time of the shooting, and that his cousin Pinoy later went to him and told him that he had shot the Valencias was disproved by Cristina, accused-appellant's sister and witness. Cristina testified that her brother, accused-appellant, did not visit her on the night of the incident. Moreover, where the defense of denial remains unsubstantiated by clear and convincing evidence, it becomes negative and self-serving, and must not be given more evidentiary value vis-à-vis the affirmative testimony of a credible witness.[23] | |||||
|
2009-09-17 |
VELASCO JR., J. |
||||
| By the peculiar nature of rape cases, conviction thereon most often rests solely on the basis of the offended party's testimony, if credible, natural, convincing, and consistent with human nature and the normal course of things.[11] Accordingly, the Court has consistently adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, albeit innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme care; and (3) the evidence for the prosecution must succeed or fall on its own merits, and cannot be allowed to derive strength from the weakness of the evidence for the defense.[12] | |||||
|
2009-08-04 |
VELASCO JR., J. |
||||
| By the distinctive nature of rape cases, conviction usually rests solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[14] Accordingly, the Court has consistently adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[15] | |||||
|
2009-03-17 |
VELASCO JR., J. |
||||
| By the distinctive nature of rape cases, conviction usually rests solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[13] Accordingly, we adhere to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the accused, though innocent, to disprove; | |||||
|
2008-09-12 |
VELASCO JR., J. |
||||
| The trial and appellate courts correctly assessed that complainant's testimony is credible; and accused-appellant has not shown any ground to make us rule otherwise. Unless it is shown that certain facts of substance and value have been plainly overlooked, misunderstood, or misapplied, the trial court's finding of credibility shall prevail.[21] | |||||
|
2008-08-22 |
BRION, J. |
||||
| Time and again, we have consistently held that when a woman states that she has been raped, she says in effect all that is necessary to show that rape was committed. For no woman, least of all a child, would weave a tale of sexual assault on her person, would open herself to examination of her private parts, and would risk a public trial and possible ridicule if she had not, in truth, been raped. That she came out in the open to complain clearly signals that she wanted to seek justice for the wrong done to her.[49] | |||||
|
2007-09-21 |
CHICO-NAZARIO, J. |
||||
| In People v. Corpuz,[27] a case where the appellant also raised this same argument, this Court stated that:It is highly inconceivable that complainant would not recognize her own father, with whom she had been living for a time. We have held that it is the most natural reaction for victims of criminal violence to strive to see the appearance of their assailant and observe the manner in which the crime was committed. Most often, the face and body movements of the assailants create a lasting impression which cannot be easily erased from their memory. The impression becomes more profound where the malefactor is the victim's own father. | |||||
|
2007-09-11 |
TINGA, J, |
||||
| Moreover, it is well-settled that a categorical and positive identification of an accused, without any showing of ill-motive on the part of the eyewitness testifying on the matter, prevails over alibi and denial, which are negative and self-serving evidence undeserving of bona fide weight in law unless substantiated by clear and convincing evidence.[25] The denial and alibi of appellants in this case are weak and cannot prevail over AAA's positive identification of them. For alibi to prosper, they must establish by clear and convincing evidence (a) their presence at another place at the time of the perpetration of the offense and (b) the physical impossibility of their presence at the scene of the crime.[26] Appellants' claim that they were in Guillermo's house two (2) kilometers away from the place of the crime does not convince us. It was not physically impossible for them to return to Upper Buli Creek and perpetrate the crime, for Guillermo's house in Carmina Compound is but a short distance away. In fact, Gingos initially testified that the distance between the two places was only 150 meters, which he curiously changed to two (2) kilometers subsequently in the course of his testimony.[27] | |||||
|
2007-04-24 |
CALLEJO, SR., J. |
||||
| At the outset, it must be stressed that in the review of rape cases, courts are guided by three principles: (1) an accusation for rape can be made with facility, and it is difficult to prove but more difficult for the accused, though innocent, to disprove; (2) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merit, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[46] | |||||
|
2006-12-06 |
CARPIO MORALES, J. |
||||
| Absent any showing that the trial judge overlooked, misunderstood, or misapplied some facts or circumstances of weight which would affect the result of the case, or that the judge acted arbitrarily, the trial judge's assessment of credibility must be respected.[27] | |||||
|
2006-10-12 |
TINGA, J. |
||||
| It has been consistently held in a long line of cases that when a woman, more so if she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape was committed.[25] In fact, the testimony of the victim alone, if credible, is sufficient to convict the accused of the crime. AAA's straightforward account of the incident categorically established the commission of the crime of rape: Q Do you remember what happened to you one evening while you were asleep in your house? | |||||