This case has been cited 8 times or more.
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2014-07-18 |
PEREZ, J. |
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| In the prosecution of rape cases, conviction or acquittal depends on the complainant's testimony because of the fact that usually only the participants are witnesses to their occurrences. The issue therefore boils down to credibility. Significantly, findings of fact of the trial court should not be disturbed on appeal since conclusions as to the credibility of witnesses in rape cases lie heavily on the sound judgment of the trial court which is in a better position to decide the question, having heard the witnesses and observed their deportment and manner of testifying.[16] | |||||
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2013-09-18 |
REYES, J. |
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| Further, the lack of resistance on the part of AAA as claimed by the accused-appellant, even assuming it to be true, does not mean that AAA willingly surrendered to his sexual desires. It bears stressing that physical resistance need not be established in rape cases when threats and intimidation are employed and the victim submits herself to the embrace of her rapist because of fear.[21] | |||||
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2009-01-30 |
CARPIO MORALES, J. |
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| At the core of almost all rape cases is the issue of credibility of witnesses. The trial court is in the best position to resolve the issue, having heard the witnesses and observed their demeanor during trial.[24] Thus, appellate courts will not disturb the credence accorded by the trial court to the testimonies of witnesses unless it is shown that the latter has overlooked or arbitrarily disregarded facts and circumstances of significance to the case.[25] This exception does not obtain in the present cases. | |||||
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2008-02-19 |
CARPIO, J. |
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| We find the appeal without merit. The Court of Appeals was correct in affirming the ruling of the trial court that the testimonies of the prosecution witnesses and the other evidence clearly established appellant's commission of the rape. The trial court, having the opportunity to observe the witnesses and their demeanor during the trial, can best assess the credibility of the witnesses and their testimonies. [3] Thus, the trial court's findings are generally binding and conclusive, absent any arbitrariness or oversight of some fact or circumstance of weight and influence.[4] | |||||
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2007-08-07 |
GARCIA, J. |
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| Appellant insists, however, that the evidence is not sufficient to establish his guilt beyond reasonable doubt, most especially the rape which allegedly occurred in 1997. But, as the two courts below found, there is enough evidence on record to sufficiently establish the occurrence of said rape. As shown in her testimony, AAA clearly and categorically stated that appellant was able to partially penetrate his penis into her vagina, and she confirmed that there was indeed such penetration because she felt pain at that time. True, there was no medical certificate presented showing any injury or lacerations in AAA's hymen; nonetheless, such does not negate the possibility of rape. Medical findings are at best corroborative and therefore not indispensable in proving the commission of the crime of rape,[19] inasmuch as the victim's testimony alone, if credible, is sufficient to convict. Besides, for rape to be consummated, full penetration is not necessary. Penile invasion necessarily entails contact with the labia and it suffices that there is proof of the entrance of the male organ with the labia of the pudendum of the female organ. Thus, penetration of the penis by entry into the lips of the vagina, even without rupture or laceration of the hymen, is enough to justify a conviction for rape.[20] Likewise, AAA's failure to specify the exact date of her rape in 1997 is immaterial considering that the exact date of commission of the rape is not an essential element of the crime. For, the gravamen of the offense of rape is the fact of carnal knowledge under any of the following circumstances: (1) by using force or intimidation; (2) when the woman is deprived of reason or otherwise unconscious; and (3) when the woman is under twelve (12) years of age or is demented.[21] Also, AAA's delay in disclosing her sexual defilement is understandable, given the fact that such procrastination was attributable to her fear for her life and that of her mother. In any event, long silence and delay in reporting the crime of rape have not always been construed as an indication of a false accusation.[22] And this principle applies with greater force where, as in this case, the victim was 10-11 years old at the time of the rape incidents, and was therefore susceptible to intimidation and threats of physical harm. | |||||
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2007-04-27 |
TINGA, J. |
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| In the prosecution of rape cases, conviction or acquittal depends on the credence to be accorded to the complainant's testimony because of the fact that usually the participants are the only witnesses to the occurrences.[19] Thus, the issue boils down to credibility. Significantly, findings of fact of the trial court should not be disturbed on appeal since conclusions as to the credibility of witnesses in rape cases hinge heavily on the sound judgment of the trial court which is in a better position to decide the question, having heard the witnesses and observed their deportment and manner of testifying.[20] | |||||
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2007-04-27 |
CARPIO MORALES, J. |
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| Finally, the increase by the appellate court to P50,000 of the amount of moral damages is, consistent with prevailing jurisprudence which has pegged the amount to P50,000 in cases of simple rape.[51] | |||||