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GR No. 189649

2015-04-20

ADORACION CAROLINO v. GEN. GENEROSO SENGA

PERALTA, J.

On August 24, 2006, Jeremias filed with the Regional Trial Court (RTC) of Quezon City, a Petition for Mandamus[9] against Gen. Generoso Senga, as Chief of Staff of the AFP, Brig. Gen. Fernando Zabat, as Chief of the AFP Finance Center, Comm. Reynaldo Basilio, as Chief of the AFP-GHQ Management and Fiscal Office, and Comm. Emilio Marayag, Pension and Gratuity Management Officer, Pension and Gratuity Management Center, AFP Finance Center, seeking reinstatement of his name in the list of the AFP retired officers, resumption of payment of his retirement benefits under RA No. 340, and the reimbursement of all his retirement pay and benefits which accrued from March 5, 2005 up to the time his name is reinstated and, thereafter, with claim for damages and attorney's fees. The case was docketed as Civil Case No. Q-06-58686, and raffled off to Branch 220.

GR No. 182794

2014-09-08

PEOPLE v. BOBBY BELGAR

BERSAMIN, J.

Like the RTC and the CA, we find AAA's narration of her ordeal as credible and truthful. The assessment by the RTC on the credibility of AAA should be respected because the trial court had personally observed her demeanor while testifying. This appreciation held true because the CA affirmed the factual findings of the RTC.[19]

GR No. 186463

2012-11-14

PEOPLE v. WILLIAM MANGUNE Y DEL ROSARIO

LEONARDO-DE CASTRO, J.

Furthermore, Mangune could not impute any ill motive on AAA or his wife that would explain why he was charged with such a heinous crime. We have ruled that "[a]bsent evidence showing any reason or motive for a witness to falsely testify against the accused, the logical conclusion is that no such improper motive exists and the testimony should be accorded full faith and credit."[39]

GR No. 182522

2012-03-07

PEOPLE v. NOEL T. ADALLOM

LEONARDO-DE CASTRO, J.

In contrast, accused-appellant proffered the defenses of denial and alibi, which are the weakest of defenses in criminal cases. The well-established rule is that denial and alibi are self-serving negative evidence; they cannot prevail over the spontaneous, positive, and credible testimonies of the prosecution witnesses who pointed to and identified the accused-appellant as the malefactor. "Indeed, alibi is easy to concoct and difficult to disprove."[44]

GR No. 181035

2011-07-04

PEOPLE v. NOEL DION

LEONARDO-DE CASTRO, J.

Dion was utterly unsuccessful in discrediting AAA's allegation that he raped her again in the evening of June 16, 2001. His claim that his version was corroborated by his witnesses is also misplaced. On the contrary, the testimonies of his witnesses were so inconsistent that rather than helping his case, his guilt was further established. For instance, while he categorically declared that he was not able to go to the dancing hall because AAA invited him to her house, his own mother testified that she herself went with Dion to the dancing hall. In addition, while they all stated that the incident happened at ten o'clock in the evening, Dion's father said that he left the hall to go to BBB's house at eight o'clock in the evening. Moreover, whereupon Dion claimed that he just happened to pass by AAA's house when AAA invited him in, Dion's father said Dion was there because AAA wanted him to accompany her to the dancing hall, while Barangay Chairman Neris said that Dion was supposed to pick up his uncle to go to the dancing hall. More than these terribly inconsistent statements, Dion himself could not substantiate his defense. In fact, he admitted that he and AAA rarely talked and that they had no quarrel. Since Dion was unable to offer evidence showing any reason or motive for AAA to falsely testify against him, the logical conclusion is that no such improper motive exists and the testimony of AAA should be accorded full faith and credit. [54]

GR No. 178406

2011-04-06

PEOPLE v. RONALDO SALUDO

LEONARDO-DE CASTRO, J.

There is no reason for us to depart from the general rule in this case. Reviewing the records of the case ourselves, we do not find any fact or circumstance overlooked, misunderstood or misapplied by the RTC, which, if considered, would have warranted a modification or reversal of the outcome of the case. Consequently, we are according high respect, if not conclusive effect, to the factual findings of the RTC, including its assessment of the credibility of the witnesses and the probative weight thereof, as well as the conclusions of the trial court based on its factual findings, especially since such findings had been affirmed by the Court of Appeals.[24]

GR No. 187503

2009-09-11

PEOPLE v. TECSON LIM Y CHUA

CHICO-NAZARIO, J.

Direct proof is not essential to prove conspiracy; it may be established by acts of the accused before, during and after the commission of the crime charged, from which may be logically inferred the existence of a common purpose to commit the same.[50]

GR No. 170137

2009-08-27

PEOPLE v. RANDY MAGBANUA

LEONARDO-DE CASTRO, J.

As long as the testimonies of the witnesses corroborate each other on material points, the minor inconsistencies therein cannot destroy their credibility.[15] Such minor inconsistencies may even serve to strengthen their credibility as they negate any suspicion that their testimonies are fabricated or rehearsed. Even the most candid of witnesses commit mistakes and make confused and inconsistent statements.[16]

GR No. 177430

2009-07-14

RENE M. FRANCISCO v. PEOPLE

CHICO-NAZARIO, J.

There was no direct evidence showing that all the accused came together and planned the crime charged. However, it is clear that their acts were in pursuance of one common criminal objective. They wanted to evade the payment of correct duties and taxes due the government. The failure of Francisco, Ojeda and Lintag to order a 100% examination of the subject importation, in spite of the glaring discrepancies and suspicious entries in the documents involved, without any doubt, facilitated the release of the importation involved by making it appear that said importation was legally done. Allowing the subject cargo to pass through Customs without a hitch clearly points to a conspiracy between and among all the accused. Their individual participation has been duly established. Since conspiracy has been proved beyond reasonable doubt, all the conspirators, regardless of their degree of participation, are criminally liable for the crime charged and proved - the act of one is the act of all.[64]

GR No. 152263

2009-07-03

ARTHUR ZARATE v. RTC

PERALTA, J.

Petitioner erred in stating that Guiritan's statement, which was admitted as part of the res gestae, was the sole basis for his conviction. Apart from the written statement, Guiritan, who survived the stabbing incident, positively identified appellant in open court and testified that petitioner was the one who stabbed him and that he knew petitioner even before the stabbing incident. Conviction of the accused may be had on the basis of the credible and positive testimony of a single witness.[20]

GR No. 171654

2008-12-17

PEOPLE v. EDWIN GAYETA Y ROBLO

TINGA, J.

The Court of Appeals correctly dismissed the inconsistencies in prosecution witness' statements for being trivial and for not having the effect of impairing her credibility as a witness. Inconsistencies as to minor details and peripheral or collateral matters do not affect the credibility of witnesses or the probative weight of their testimonies. Such minor inconsistencies may even serve to strengthen their credibility, as they negate any suspicion that their testimonies are fabricated or rehearsed.[28]

GR No. 177571

2008-09-29

PEOPLE v. DEAN MARTIN Y SARVIDA

VELASCO JR., J.

We hold further that the CA correctly ruled that there was conspiracy between accused-appellants in committing the crime. Conspiracy exists when two or more persons agree to commit a felony and decide to commit it.[17] Direct proof is not essential to prove conspiracy; it may be deduced by acts of the accused before, during, and after the commission of the crime charged, from which it may be indicated that there is a common purpose to commit the crime.[18] In this case, while Martin did not take part in stabbing the victim, his act of stopping Dolores from seeking help implied his assent to Tanoan's act and ensured the completion of the criminal act.

GR NO. 155153

2007-07-24

SPO1 LORETO NERPIO v. PEOPLE

VELASCO, JR., J.

Also, denial is a negative, self-serving evidence that cannot prevail over the positive and categorical assertion of a credible witness that accused perpetrated the crime.[28] In this case, petitioner has not given strong evidence of his inculpability.

GR NO. 172966

2007-02-08

PEOPLE v. EUGENIO PILIIN Y GARCIA

TINGA, J.

The conviction of appellant, as well as the appreciation of treachery, was based on the testimony of Norma, an eyewitness to the shooting of her husband. We reiterate the rule that factual findings of the trial court, especially when affirmed by the appellate court, are binding on us. The trial court's evaluation of the testimonies of witnesses is accorded great respect because it had the opportunity to observe the demeanor and conduct of witnesses on the stand.[20]

GR NO. 170470

2006-09-26

PEOPLE v. EDNA MALNGAN Y MAYO

CHICO-NAZARIO, J.

Apropos the civil liabilities of accused-appellant, current jurisprudence[58] dictate that the civil indemnity due from accused-appellant is P50,000.00 for the death of each of the victims.[59] However, the monetary awards for moral and exemplary damages given by the Court of Appeals, both in the amount of P50,000.00, due the heirs of the victims, have to be deleted for lack of material basis. Similarly, the Court of Appeals award of exemplary damages to Rodolfo Movilla in the amount of P50,000.00 for the destruction of his house, also has to be deleted, but in this instance for being improper. Moral damages cannot be award by this Court in the absence of proof of mental or physical suffering on the part of the heirs of the victims.[60] Concerning the award of exemplary damages, the reason for the deletion being that no aggravating circumstance had been alleged and proved by the prosecution in the case at bar.[61]

GR NO. 160858

2006-02-28

ROLITO RABANAL v. PEOPLE

TINGA, J.

The trial court disregarded these apparent inconsistencies and upheld the general credibility of the witness who appeared to be sincere.[24] We are well aware of the rule that minor inconsistencies and contradictions do not destroy the credibility of the witness. In fact, they even tend to strengthen rather than weaken one's credibility by erasing any suspicion of a rehearsed testimony.[25]

	GR No. 189649 2015-04-20	ADORACION CAROLINO v. GEN. GENEROSO SENGA PERALTA, J.
On August 24, 2006, Jeremias filed with the Regional Trial Court (RTC) of Quezon City, a Petition for Mandamus[9] against Gen. Generoso Senga, as Chief of Staff of the AFP, Brig. Gen. Fernando Zabat, as Chief of the AFP Finance Center, Comm. Reynaldo Basilio, as Chief of the AFP-GHQ Management and Fiscal Office, and Comm. Emilio Marayag, Pension and Gratuity Management Officer, Pension and Gratuity Management Center, AFP Finance Center, seeking reinstatement of his name in the list of the AFP retired officers, resumption of payment of his retirement benefits under RA No. 340, and the reimbursement of all his retirement pay and benefits which accrued from March 5, 2005 up to the time his name is reinstated and, thereafter, with claim for damages and attorney's fees. The case was docketed as Civil Case No. Q-06-58686, and raffled off to Branch 220.
	GR No. 182794 2014-09-08	PEOPLE v. BOBBY BELGAR BERSAMIN, J.
Like the RTC and the CA, we find AAA's narration of her ordeal as credible and truthful. The assessment by the RTC on the credibility of AAA should be respected because the trial court had personally observed her demeanor while testifying. This appreciation held true because the CA affirmed the factual findings of the RTC.[19]
	GR No. 186463 2012-11-14	PEOPLE v. WILLIAM MANGUNE Y DEL ROSARIO LEONARDO-DE CASTRO, J.
Furthermore, Mangune could not impute any ill motive on AAA or his wife that would explain why he was charged with such a heinous crime. We have ruled that "[a]bsent evidence showing any reason or motive for a witness to falsely testify against the accused, the logical conclusion is that no such improper motive exists and the testimony should be accorded full faith and credit."[39]
	GR No. 182522 2012-03-07	PEOPLE v. NOEL T. ADALLOM LEONARDO-DE CASTRO, J.
In contrast, accused-appellant proffered the defenses of denial and alibi, which are the weakest of defenses in criminal cases. The well-established rule is that denial and alibi are self-serving negative evidence; they cannot prevail over the spontaneous, positive, and credible testimonies of the prosecution witnesses who pointed to and identified the accused-appellant as the malefactor. "Indeed, alibi is easy to concoct and difficult to disprove."[44]
	GR No. 181035 2011-07-04	PEOPLE v. NOEL DION LEONARDO-DE CASTRO, J.
Dion was utterly unsuccessful in discrediting AAA's allegation that he raped her again in the evening of June 16, 2001. His claim that his version was corroborated by his witnesses is also misplaced. On the contrary, the testimonies of his witnesses were so inconsistent that rather than helping his case, his guilt was further established. For instance, while he categorically declared that he was not able to go to the dancing hall because AAA invited him to her house, his own mother testified that she herself went with Dion to the dancing hall. In addition, while they all stated that the incident happened at ten o'clock in the evening, Dion's father said that he left the hall to go to BBB's house at eight o'clock in the evening. Moreover, whereupon Dion claimed that he just happened to pass by AAA's house when AAA invited him in, Dion's father said Dion was there because AAA wanted him to accompany her to the dancing hall, while Barangay Chairman Neris said that Dion was supposed to pick up his uncle to go to the dancing hall. More than these terribly inconsistent statements, Dion himself could not substantiate his defense. In fact, he admitted that he and AAA rarely talked and that they had no quarrel. Since Dion was unable to offer evidence showing any reason or motive for AAA to falsely testify against him, the logical conclusion is that no such improper motive exists and the testimony of AAA should be accorded full faith and credit. [54]
	GR No. 178406 2011-04-06	PEOPLE v. RONALDO SALUDO LEONARDO-DE CASTRO, J.
There is no reason for us to depart from the general rule in this case. Reviewing the records of the case ourselves, we do not find any fact or circumstance overlooked, misunderstood or misapplied by the RTC, which, if considered, would have warranted a modification or reversal of the outcome of the case. Consequently, we are according high respect, if not conclusive effect, to the factual findings of the RTC, including its assessment of the credibility of the witnesses and the probative weight thereof, as well as the conclusions of the trial court based on its factual findings, especially since such findings had been affirmed by the Court of Appeals.[24]
	GR No. 187503 2009-09-11	PEOPLE v. TECSON LIM Y CHUA CHICO-NAZARIO, J.
Direct proof is not essential to prove conspiracy; it may be established by acts of the accused before, during and after the commission of the crime charged, from which may be logically inferred the existence of a common purpose to commit the same.[50]
	GR No. 170137 2009-08-27	PEOPLE v. RANDY MAGBANUA LEONARDO-DE CASTRO, J.
As long as the testimonies of the witnesses corroborate each other on material points, the minor inconsistencies therein cannot destroy their credibility.[15] Such minor inconsistencies may even serve to strengthen their credibility as they negate any suspicion that their testimonies are fabricated or rehearsed. Even the most candid of witnesses commit mistakes and make confused and inconsistent statements.[16]
	GR No. 177430 2009-07-14	RENE M. FRANCISCO v. PEOPLE CHICO-NAZARIO, J.
There was no direct evidence showing that all the accused came together and planned the crime charged. However, it is clear that their acts were in pursuance of one common criminal objective. They wanted to evade the payment of correct duties and taxes due the government. The failure of Francisco, Ojeda and Lintag to order a 100% examination of the subject importation, in spite of the glaring discrepancies and suspicious entries in the documents involved, without any doubt, facilitated the release of the importation involved by making it appear that said importation was legally done. Allowing the subject cargo to pass through Customs without a hitch clearly points to a conspiracy between and among all the accused. Their individual participation has been duly established. Since conspiracy has been proved beyond reasonable doubt, all the conspirators, regardless of their degree of participation, are criminally liable for the crime charged and proved - the act of one is the act of all.[64]
	GR No. 152263 2009-07-03	ARTHUR ZARATE v. RTC PERALTA, J.
Petitioner erred in stating that Guiritan's statement, which was admitted as part of the res gestae, was the sole basis for his conviction. Apart from the written statement, Guiritan, who survived the stabbing incident, positively identified appellant in open court and testified that petitioner was the one who stabbed him and that he knew petitioner even before the stabbing incident. Conviction of the accused may be had on the basis of the credible and positive testimony of a single witness.[20]
	GR No. 171654 2008-12-17	PEOPLE v. EDWIN GAYETA Y ROBLO TINGA, J.
The Court of Appeals correctly dismissed the inconsistencies in prosecution witness' statements for being trivial and for not having the effect of impairing her credibility as a witness. Inconsistencies as to minor details and peripheral or collateral matters do not affect the credibility of witnesses or the probative weight of their testimonies. Such minor inconsistencies may even serve to strengthen their credibility, as they negate any suspicion that their testimonies are fabricated or rehearsed.[28]
	GR No. 177571 2008-09-29	PEOPLE v. DEAN MARTIN Y SARVIDA VELASCO JR., J.
We hold further that the CA correctly ruled that there was conspiracy between accused-appellants in committing the crime. Conspiracy exists when two or more persons agree to commit a felony and decide to commit it.[17] Direct proof is not essential to prove conspiracy; it may be deduced by acts of the accused before, during, and after the commission of the crime charged, from which it may be indicated that there is a common purpose to commit the crime.[18] In this case, while Martin did not take part in stabbing the victim, his act of stopping Dolores from seeking help implied his assent to Tanoan's act and ensured the completion of the criminal act.
	GR NO. 155153 2007-07-24	SPO1 LORETO NERPIO v. PEOPLE VELASCO, JR., J.
Also, denial is a negative, self-serving evidence that cannot prevail over the positive and categorical assertion of a credible witness that accused perpetrated the crime.[28] In this case, petitioner has not given strong evidence of his inculpability.
	GR NO. 172966 2007-02-08	PEOPLE v. EUGENIO PILIIN Y GARCIA TINGA, J.
The conviction of appellant, as well as the appreciation of treachery, was based on the testimony of Norma, an eyewitness to the shooting of her husband. We reiterate the rule that factual findings of the trial court, especially when affirmed by the appellate court, are binding on us. The trial court's evaluation of the testimonies of witnesses is accorded great respect because it had the opportunity to observe the demeanor and conduct of witnesses on the stand.[20]
	GR NO. 170470 2006-09-26	PEOPLE v. EDNA MALNGAN Y MAYO CHICO-NAZARIO, J.
Apropos the civil liabilities of accused-appellant, current jurisprudence[58] dictate that the civil indemnity due from accused-appellant is P50,000.00 for the death of each of the victims.[59] However, the monetary awards for moral and exemplary damages given by the Court of Appeals, both in the amount of P50,000.00, due the heirs of the victims, have to be deleted for lack of material basis. Similarly, the Court of Appeals award of exemplary damages to Rodolfo Movilla in the amount of P50,000.00 for the destruction of his house, also has to be deleted, but in this instance for being improper. Moral damages cannot be award by this Court in the absence of proof of mental or physical suffering on the part of the heirs of the victims.[60] Concerning the award of exemplary damages, the reason for the deletion being that no aggravating circumstance had been alleged and proved by the prosecution in the case at bar.[61]
	GR NO. 160858 2006-02-28	ROLITO RABANAL v. PEOPLE TINGA, J.
The trial court disregarded these apparent inconsistencies and upheld the general credibility of the witness who appeared to be sincere.[24] We are well aware of the rule that minor inconsistencies and contradictions do not destroy the credibility of the witness. In fact, they even tend to strengthen rather than weaken one's credibility by erasing any suspicion of a rehearsed testimony.[25]

PEOPLE v. JOSE BULAN