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GR No. 181138

2012-12-03

DEL CASTILLO, J.

Besides, it is established that the assessment on the credibility of witnesses is a function best discharged by the trial court due to its position to observe the behavior and demeanor of the witness in court.[65] This rule is set aside only when the trial court's evaluation was reached arbitrarily, or when it "overlooked, misunderstood or misapplied certain facts or circumstances of weight and substance which could affect the result of the case."[66] Here, no such situation occurred.

GR No. 188855

2010-12-08

PEOPLE v. RUEL TAMANO Y PASIA

PEREZ, J.

In essence, the crime of rape involves two persons only and it is usually perpetrated in seclusion, thus, the credibility of the victim is crucial to the determination of the culpability of the accused.[44]

GR No. 186533

2010-08-09

PEOPLE v. EFREN CASTILLO

PEREZ, J.

It is also worth stressing that during AAA's testimony, she positively identified the appellant as the person who had raped her.[44] Thus, the straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[45]

GR No. 186411

2010-07-05

PEOPLE v. ARTURO PALER

VELASCO JR., J.

Appellant attacks the victim's capacity to testify based on her weak mental condition. However, as correctly held by the appellate court, mental retardation, by itself, does not disqualify a person from testifying. What is essential is the quality of perception, and the manner in which this perception is made known to the court.[17] In this case, records show that despite the victim's mental retardation, she testified in a straightforward and categorical manner that appellant had raped her. The defense could not even shake her resolve to implicate appellant in the crime. On the contrary, her statements during cross-examination even support her position. There is thus, no reason to overturn the finding of credibility by the trial and appellate courts.

GR No. 182687

2009-07-23

PEOPLE v. WARLITO MARTINEZ

VELASCO JR., J.

It is a basic doctrine that anyone who can perceive, and perceiving, can make known such perception to others, may be a witness.[15] Thus, by itself, mental retardation does not disqualify a person from testifying. What is essential is the quality of perception, and the manner in which this perception is made known to the court.[16]

GR No. 180500

2008-09-11

PEOPLE v. MEDARDO CRESPO Y CRUZ

CHICO-NAZARIO, J.

Finally, AAA positively identified[69] the appellant as her ravisher. The straightforward narration by AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[70] No daughter will charge a father, especially a good father, with rape. The charge is not only embarrassing to the victim and the family, it means death to the head of the family.[71]

GR No. 179277

2008-06-18

PEOPLE v. REMON COJA Y SIMEON

TINGA, J,

As a general rule, the findings of the trial court relative to the credibility of the rape victim are normally respected and not disturbed on appeal. More so, if they are affirmed by the appellate court. [23] It is only in exceptional circumstances that this rule is brushed aside, such as when the court's evaluation was reached arbitrarily, or when the trial court overlooked, misunderstood or misapplied certain facts or circumstances of weight and substance which could affect the result of the case.[24] The Court does not find any of these exceptions in the case at bar.

GR No. 176742

2008-06-17

PEOPLE v. WENCESLAO ESPINO

CHICO-NAZARIO, J.

Jurisprudence has steadfastly been already repetitious that the accused may be convicted on the sole testimony of the victim in a rape case, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[58] In the case at bar, as is being heretofore emphasized, AAA testified in a direct, unequivocal, and consistent manner with regard to the rape committed against her by the appellant. The straightforward narration by AAA of what transpired, accompanied by her categorical identification[59] of appellant as the malefactor, sealed the case for the prosecution.[60]

GR No. 176065

2008-04-22

PEOPLE v. RAMON ARIVAN Y FORNILLO

CHICO-NAZARIO, J.

As can be gleaned from the records of the present case, when AAA testified in court, her testimony described in details the hideous experience she suffered on 31 December 1998 in the hands of the appellant. In her narration on the manner of how the appellant took advantage of her, she never wavered in her testimony. The trial court characterized AAA's testimony as straightforward, categorical and candid. Further, during her testimony before the court a quo, she cried[42] whenever she had to recall and narrate what happened to her. The crying of a victim during her testimony is evidence of the truth of the rape charges, for the display of such emotion indicates the pain that the victim feels when asked to recount her traumatic experience.[43] And, as the trial court mentioned in its Decision, AAA exhibited courage and conviction in prosecuting the case. She gladly cooperated with the court a quo during the ocular inspection of the place where the rape incident happened, knowing that she had to go back to see the place where she had been abused by the appellant. Moreso, during AAA's testimony before the trial court, she positively identified the appellant as her ravisher. The straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[44] Also, it was not shown that she had been motivated by any ill desire that would make her testify falsely against the accused. Given the foregoing, it is beyond doubt that AAA's testimony is credible and the prosecution was able to prove the guilt of the appellant beyond reasonable doubt.

GR No. 177756

2008-03-03

PEOPLE v. SALVADOR NIETO y CABALSE

CHICO-NAZARIO, J.

As can be gleaned from the records of this case, this Court notes that the testimony given by AAA before the trial court can be characterized as categorical and straightforward. She was able to describe before the court a quo how she was ravished by the appellant on 30 December 1999 and 3 January 2000. She even demonstrated the sexual act by spreading her two legs and placing her finger to her vagina.[36] And during her testimony, she positively identified the appellant as the person who had raped her on the aforesaid dates.[37] The straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[38] Further, it was not shown that she had been motivated by any ill desire that would make her testify falsely against the accused. Moreover, having the mental age of a five-year-and-three-month-old child would even bolster her credibility as a witness considering that a victim at such tender age would not publicly admit that she had been criminally abused and ravished unless that was the truth. For no woman, especially one of tender age, practically only a girl, would concoct a story of defloration, allow an examination of her private parts and thereafter expose herself to a public trial, if she were not motivated solely by the desire to have the culprit apprehended and punished to avenge her honor and to condemn a grave injustice to her.[39]

GR NO. 172322

2006-09-08

PEOPLE v. RENE SANTOS

TINGA, J.

We have examined the evidence on record and find no cogent reason to disturb the findings of the trial court and the Court of Appeals. We accord great respect on the findings of the trial court on the credibility of witnesses and their testimonies, for the trial judge observes the behavior and demeanor of the witnesses in court. His evaluation or assessment of the credibility of witnesses and of testimony acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony."[25]

	GR No. 181138 2012-12-03	RICKY “TOTSIE” MARQUEZ v. PEOPLE DEL CASTILLO, J.
Besides, it is established that the assessment on the credibility of witnesses is a function best discharged by the trial court due to its position to observe the behavior and demeanor of the witness in court.[65] This rule is set aside only when the trial court's evaluation was reached arbitrarily, or when it "overlooked, misunderstood or misapplied certain facts or circumstances of weight and substance which could affect the result of the case."[66] Here, no such situation occurred.
	GR No. 188855 2010-12-08	PEOPLE v. RUEL TAMANO Y PASIA PEREZ, J.
In essence, the crime of rape involves two persons only and it is usually perpetrated in seclusion, thus, the credibility of the victim is crucial to the determination of the culpability of the accused.[44]
	GR No. 186533 2010-08-09	PEOPLE v. EFREN CASTILLO PEREZ, J.
It is also worth stressing that during AAA's testimony, she positively identified the appellant as the person who had raped her.[44] Thus, the straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[45]
	GR No. 186411 2010-07-05	PEOPLE v. ARTURO PALER VELASCO JR., J.
Appellant attacks the victim's capacity to testify based on her weak mental condition. However, as correctly held by the appellate court, mental retardation, by itself, does not disqualify a person from testifying. What is essential is the quality of perception, and the manner in which this perception is made known to the court.[17] In this case, records show that despite the victim's mental retardation, she testified in a straightforward and categorical manner that appellant had raped her. The defense could not even shake her resolve to implicate appellant in the crime. On the contrary, her statements during cross-examination even support her position. There is thus, no reason to overturn the finding of credibility by the trial and appellate courts.
	GR No. 182687 2009-07-23	PEOPLE v. WARLITO MARTINEZ VELASCO JR., J.
It is a basic doctrine that anyone who can perceive, and perceiving, can make known such perception to others, may be a witness.[15] Thus, by itself, mental retardation does not disqualify a person from testifying. What is essential is the quality of perception, and the manner in which this perception is made known to the court.[16]
	GR No. 180500 2008-09-11	PEOPLE v. MEDARDO CRESPO Y CRUZ CHICO-NAZARIO, J.
Finally, AAA positively identified[69] the appellant as her ravisher. The straightforward narration by AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[70] No daughter will charge a father, especially a good father, with rape. The charge is not only embarrassing to the victim and the family, it means death to the head of the family.[71]
	GR No. 179277 2008-06-18	PEOPLE v. REMON COJA Y SIMEON TINGA, J,
As a general rule, the findings of the trial court relative to the credibility of the rape victim are normally respected and not disturbed on appeal. More so, if they are affirmed by the appellate court. [23] It is only in exceptional circumstances that this rule is brushed aside, such as when the court's evaluation was reached arbitrarily, or when the trial court overlooked, misunderstood or misapplied certain facts or circumstances of weight and substance which could affect the result of the case.[24] The Court does not find any of these exceptions in the case at bar.
	GR No. 176742 2008-06-17	PEOPLE v. WENCESLAO ESPINO CHICO-NAZARIO, J.
Jurisprudence has steadfastly been already repetitious that the accused may be convicted on the sole testimony of the victim in a rape case, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[58] In the case at bar, as is being heretofore emphasized, AAA testified in a direct, unequivocal, and consistent manner with regard to the rape committed against her by the appellant. The straightforward narration by AAA of what transpired, accompanied by her categorical identification[59] of appellant as the malefactor, sealed the case for the prosecution.[60]
	GR No. 176065 2008-04-22	PEOPLE v. RAMON ARIVAN Y FORNILLO CHICO-NAZARIO, J.
As can be gleaned from the records of the present case, when AAA testified in court, her testimony described in details the hideous experience she suffered on 31 December 1998 in the hands of the appellant. In her narration on the manner of how the appellant took advantage of her, she never wavered in her testimony. The trial court characterized AAA's testimony as straightforward, categorical and candid. Further, during her testimony before the court a quo, she cried[42] whenever she had to recall and narrate what happened to her. The crying of a victim during her testimony is evidence of the truth of the rape charges, for the display of such emotion indicates the pain that the victim feels when asked to recount her traumatic experience.[43] And, as the trial court mentioned in its Decision, AAA exhibited courage and conviction in prosecuting the case. She gladly cooperated with the court a quo during the ocular inspection of the place where the rape incident happened, knowing that she had to go back to see the place where she had been abused by the appellant. Moreso, during AAA's testimony before the trial court, she positively identified the appellant as her ravisher. The straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[44] Also, it was not shown that she had been motivated by any ill desire that would make her testify falsely against the accused. Given the foregoing, it is beyond doubt that AAA's testimony is credible and the prosecution was able to prove the guilt of the appellant beyond reasonable doubt.
	GR No. 177756 2008-03-03	PEOPLE v. SALVADOR NIETO y CABALSE CHICO-NAZARIO, J.
As can be gleaned from the records of this case, this Court notes that the testimony given by AAA before the trial court can be characterized as categorical and straightforward. She was able to describe before the court a quo how she was ravished by the appellant on 30 December 1999 and 3 January 2000. She even demonstrated the sexual act by spreading her two legs and placing her finger to her vagina.[36] And during her testimony, she positively identified the appellant as the person who had raped her on the aforesaid dates.[37] The straightforward narration of AAA of what transpired, accompanied by her categorical identification of appellant as the malefactor, sealed the case for the prosecution.[38] Further, it was not shown that she had been motivated by any ill desire that would make her testify falsely against the accused. Moreover, having the mental age of a five-year-and-three-month-old child would even bolster her credibility as a witness considering that a victim at such tender age would not publicly admit that she had been criminally abused and ravished unless that was the truth. For no woman, especially one of tender age, practically only a girl, would concoct a story of defloration, allow an examination of her private parts and thereafter expose herself to a public trial, if she were not motivated solely by the desire to have the culprit apprehended and punished to avenge her honor and to condemn a grave injustice to her.[39]
	GR NO. 172322 2006-09-08	PEOPLE v. RENE SANTOS TINGA, J.
We have examined the evidence on record and find no cogent reason to disturb the findings of the trial court and the Court of Appeals. We accord great respect on the findings of the trial court on the credibility of witnesses and their testimonies, for the trial judge observes the behavior and demeanor of the witnesses in court. His evaluation or assessment of the credibility of witnesses and of testimony acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony."[25]

PEOPLE v. JESUS MACAPAL