Lawyerly

GR No. 198789

2013-06-03

REYES, J.

Bernardo asserts alibi and denial as defenses. He argues that he was in jail when the crime was committed. Such alibi, while corroborated by the testimonies of some of Batac District Jail guards, cannot prevail over the positive identification made by Reah pinpointing Bernardo as one of the malefactors who shot Efren to death. The identification of Bernardo as an assailant was positively and credibly established by the prosecution in this case. It has been settled that affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness.[17] Absent clear and convincing evidence, alibi and denial are negative and self-serving evidence undeserving of weight in law.[18]

GR No. 181902

2011-08-31

PEOPLE v. EDGAR EVANGELIO Y GALLO

PERALTA, J.

Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted. [10] Denial cannot prevail over the positive testimony of prosecution witnesses who were not shown to have any ill-motive to testify against the appellant.[11]

GR No. 178771

2011-06-08

PEOPLE v. ALBERTO ANTICAMARA Y CABILLO

PERALTA, J.

Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted. [26] Denial cannot prevail over the positive testimony of prosecution witnesses who were not shown to have any ill-motive to testify against the appellants. [27]

GR No. 185726

2009-10-16

PEOPLE v. DARWIN BERNABE Y GARCIA

LEONARDO-DE CASTRO, J.

In People v. Togahan,[26] the Court likewise held: While witnesses may differ in their recollections of an incident, it does not necessarily follow from their disagreement that all of them should be disbelieved as liars and their testimonies completely discarded as worthless. As long as the mass of testimony jibes on material points, the slight clashing statements neither dilute the witnesses' credibility nor the veracity of their testimony, for indeed, such inconsistencies are but natural and even enhance credibility as these discrepancies indicate that the responses are honest and unrehearsed.

GR No. 180594

2009-08-19

PEOPLE v. VS.ISMAEL MOKAMMAD

NACHURA, J.

We agree with the courts below that the alibi resorted to by appellants is worthless in the face of the positive identification by the victims. The surviving victims were found not to have any reason to falsely testify against appellants. Admittedly, the surviving victims had no grudge against appellants. It is unnatural for victims interested in vindicating a crime to accuse somebody other than the real culprits. Human nature tells us that the aggrieved parties would want the real culprits punished, and not accept a mere scapegoat to take the rap for the real malefactors.[20]

GR No. 180594

2009-08-19

PEOPLE v. VS.ISMAEL MOKAMMAD

NACHURA, J.

Jurisprudence teems with pronouncements that between the categorical statements of the prosecution witnesses, on one hand, and the bare denial of appellants, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative one, especially when it comes from the mouth of credible witnesses. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[23] Accordingly, we affirm the RTC and the CA in giving full faith and credence to the testimonies of the surviving victims.

GR No. 170222

2009-06-18

EDGAR ESQUEDA v. PEOPLE

MENDOZA, J.

Between the categorical statements of the prosecution witnesses and the bare denial of the petitioner, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony, especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[16] In light of the foregoing, the defense of denial collapses.

GR No. 181901

2008-11-28

PEOPLE v. EMILIO MANCHU

NACHURA, J.

Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted.[22] Appellant's challenge of his conviction is starkly puerile.

GR No. 177571

2008-09-29

PEOPLE v. DEAN MARTIN Y SARVIDA

VELASCO JR., J.

When an accused challenges the witness' identification of the perpetrators, the credibility of the witness is put to doubt. As a general rule, the findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood, or misapplied some facts or circumstances of weight and substance which would have affected the result of the case.[9]

GR No. 178540

2008-06-27

PEOPLE v. ALEJANDRO SORILA

YNARES-SATIAGO, J.

Although the employees of Canscor Construction and Development Corporation were taken by surprise when the robbery took place, they were able to get a good look at the robbers who went inside the office. The most natural reaction of victims of violence is to strive to see the looks and faces of the malefactors and to observe the manner in which the crime was committed.[8] Most often, the face and body movements of the assailants create a lasting impression on the victims' minds which cannot be easily erased from their memory.[9] In fact, experience dictates that precisely because of the startling acts of violence committed in their presence, eyewitnesses can recall with a high degree of reliability the identities of the criminals and how at any given time, the crime has been committed by them. [10] Witnesses need not know the names of the malefactors as long as they recognize their faces. [11] What is imperative is that the witnesses are positive as to the perpetrators' physical identification from the witnesses' own personal knowledge, as is obtaining in this case.[12]

GR No. 177299

2007-11-28

PEOPLE v. CHARLITO TUMULAK

NACHURA, J.

Furthermore, appellant failed to show that Regalada was prompted by any ill motive to falsely testify or accuse him of killing his father. Appellant himself admitted that he had a good relationship with his stepmother. The Court adheres to the established rule that, in the absence of any evidence showing reason or motive for the witness to perjure, their testimony and identification of the assailant should be given full faith and credit.[15]

	GR No. 198789 2013-06-03	PEOPLE v. REGGIE BERNARDO REYES, J.
Bernardo asserts alibi and denial as defenses. He argues that he was in jail when the crime was committed. Such alibi, while corroborated by the testimonies of some of Batac District Jail guards, cannot prevail over the positive identification made by Reah pinpointing Bernardo as one of the malefactors who shot Efren to death. The identification of Bernardo as an assailant was positively and credibly established by the prosecution in this case. It has been settled that affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness.[17] Absent clear and convincing evidence, alibi and denial are negative and self-serving evidence undeserving of weight in law.[18]
	GR No. 181902 2011-08-31	PEOPLE v. EDGAR EVANGELIO Y GALLO PERALTA, J.
Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted. [10] Denial cannot prevail over the positive testimony of prosecution witnesses who were not shown to have any ill-motive to testify against the appellant.[11]
	GR No. 178771 2011-06-08	PEOPLE v. ALBERTO ANTICAMARA Y CABILLO PERALTA, J.
Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted. [26] Denial cannot prevail over the positive testimony of prosecution witnesses who were not shown to have any ill-motive to testify against the appellants. [27]
	GR No. 185726 2009-10-16	PEOPLE v. DARWIN BERNABE Y GARCIA LEONARDO-DE CASTRO, J.
In People v. Togahan,[26] the Court likewise held: While witnesses may differ in their recollections of an incident, it does not necessarily follow from their disagreement that all of them should be disbelieved as liars and their testimonies completely discarded as worthless. As long as the mass of testimony jibes on material points, the slight clashing statements neither dilute the witnesses' credibility nor the veracity of their testimony, for indeed, such inconsistencies are but natural and even enhance credibility as these discrepancies indicate that the responses are honest and unrehearsed.
	GR No. 180594 2009-08-19	PEOPLE v. VS.ISMAEL MOKAMMAD NACHURA, J.
We agree with the courts below that the alibi resorted to by appellants is worthless in the face of the positive identification by the victims. The surviving victims were found not to have any reason to falsely testify against appellants. Admittedly, the surviving victims had no grudge against appellants. It is unnatural for victims interested in vindicating a crime to accuse somebody other than the real culprits. Human nature tells us that the aggrieved parties would want the real culprits punished, and not accept a mere scapegoat to take the rap for the real malefactors.[20]
	GR No. 180594 2009-08-19	PEOPLE v. VS.ISMAEL MOKAMMAD NACHURA, J.
Jurisprudence teems with pronouncements that between the categorical statements of the prosecution witnesses, on one hand, and the bare denial of appellants, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative one, especially when it comes from the mouth of credible witnesses. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[23] Accordingly, we affirm the RTC and the CA in giving full faith and credence to the testimonies of the surviving victims.
	GR No. 170222 2009-06-18	EDGAR ESQUEDA v. PEOPLE MENDOZA, J.
Between the categorical statements of the prosecution witnesses and the bare denial of the petitioner, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony, especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[16] In light of the foregoing, the defense of denial collapses.
	GR No. 181901 2008-11-28	PEOPLE v. EMILIO MANCHU NACHURA, J.
Between the categorical statements of the prosecution witness, on one hand, and the bare denial of the appellant, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted.[22] Appellant's challenge of his conviction is starkly puerile.
	GR No. 177571 2008-09-29	PEOPLE v. DEAN MARTIN Y SARVIDA VELASCO JR., J.
When an accused challenges the witness' identification of the perpetrators, the credibility of the witness is put to doubt. As a general rule, the findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood, or misapplied some facts or circumstances of weight and substance which would have affected the result of the case.[9]
	GR No. 178540 2008-06-27	PEOPLE v. ALEJANDRO SORILA YNARES-SATIAGO, J.
Although the employees of Canscor Construction and Development Corporation were taken by surprise when the robbery took place, they were able to get a good look at the robbers who went inside the office. The most natural reaction of victims of violence is to strive to see the looks and faces of the malefactors and to observe the manner in which the crime was committed.[8] Most often, the face and body movements of the assailants create a lasting impression on the victims' minds which cannot be easily erased from their memory.[9] In fact, experience dictates that precisely because of the startling acts of violence committed in their presence, eyewitnesses can recall with a high degree of reliability the identities of the criminals and how at any given time, the crime has been committed by them. [10] Witnesses need not know the names of the malefactors as long as they recognize their faces. [11] What is imperative is that the witnesses are positive as to the perpetrators' physical identification from the witnesses' own personal knowledge, as is obtaining in this case.[12]
	GR No. 177299 2007-11-28	PEOPLE v. CHARLITO TUMULAK NACHURA, J.
Furthermore, appellant failed to show that Regalada was prompted by any ill motive to falsely testify or accuse him of killing his father. Appellant himself admitted that he had a good relationship with his stepmother. The Court adheres to the established rule that, in the absence of any evidence showing reason or motive for the witness to perjure, their testimony and identification of the assailant should be given full faith and credit.[15]

PEOPLE v. HENRY TOGAHAN