Lawyerly

GR No. 208760

2014-04-23

MENDOZA, J.

Jurisprudence is replete with cases where the Court ruled that questions on the credibility of witnesses should best be addressed to the trial court because of its unique position to observe that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which is denied to the appellate courts.[12] The trial judge has the advantage of actually examining both real and testimonial evidence including the demeanor of the witnesses. Hence, the judge's assessment of the witnesses' testimonies and findings of fact are accorded great respect on appeal. In the absence of any substantial reason to justify the reversal of the trial court's assessment and conclusion, as when no significant facts and circumstances are shown to have been overlooked or disregarded, the reviewing court is generally bound by the former's findings.[13] The rule is even more stringently applied if the appellate court has concurred with the trial court.

GR No. 192239

2013-06-05

PEOPLE v. RICARDO PAMINTUAN Y SAHAGUN

LEONARDO-DE CASTRO, J.

The accused-appellant's bare denial of the crime charged is insufficient to exculpate him. Well established is the rule that "a mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crimes attributed to him."[30] The Court also finds unconvincing the reason ascribed by accused-appellant on the part of AAA to accuse him of rape, i.e., that AAA and her siblings disapproved of him as their mother's common-law husband. We find this argument flimsy and totally bereft of any corroboration. We already ruled that "[m]otives such as resentment, hatred, or revenge have never swayed this Court from giving full credence to the testimony of a minor rape victim. Further, ill motives become inconsequential if the rape victim gave an affirmative and credible declaration, which clearly established the liability of the accused."[31]

GR No. 186499

2012-03-21

PEOPLE v. MELECIO DE LOS SANTOS

LEONARDO-DE CASTRO, J.

The defense of denial on the part of the accused-appellant cannot likewise exculpate him in the case at bar. The accused-appellant testified that on the afternoon of February 14, 1995, the accused-appellant claimed that he was at their house in Escalante, Negros attending to his sick father Melecio de los Santos, Sr. He even alleged that his father died on February 20, 1995. He further stated that he did not go back to XXX in the year 1995. He contended that the last time he went to the house of AAA was on September 2, 1997 when he informed them of his impending marriage. He stated that he indeed got married on September 10, 1997. The Court notes that the above testimony of the accused-appellant was without any substantial corroboration. The death certificate of Melecio de los Santos, Sr. and the marriage certificate of the accused-appellant, which were offered in evidence to support the accused-appellant's claims, were not squarely in point. The said certificates evidenced only the fact of death of Melecio de los Santos, Sr. and the fact of marriage of the accused-appellant, respectively, and in no way proved with certainty the whereabouts of the accused-appellant on the date the incident of rape was committed. In People v. Nieto,[54] we stressed that "[i]t is an established jurisprudential rule that a mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crimes attributed to him."[55] The accused- appellant likewise failed to impute any ill motive on the part of the prosecution witnesses that would have impelled them to prevaricate and charge him falsely.

GR No. 181497

2012-02-22

PEOPLE v. PATERNO SARMIENTO SAMANDRE

LEONARDO-DE CASTRO, J.

The issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts"[34] and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[35] The Court of Appeals further affirmed the findings of the RTC. In this regard, it is settled that when the findings of the trial court have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court. [36] The Court finds no compelling reason herein to deviate from said findings.

GR No. 182412

2011-11-28

PEOPLE v. PROMULGATED: JOJO DELA PAZ Y TABOCAN

BRION, J.

We likewise affirm the CA's award of moral damages in the amount of P50,000.00. Moral damages are awarded to rape victims without need of proof other than the fact of rape, as the victim suffered moral injuries from the experience she underwent.[27]

GR No. 178321

2011-10-05

PEOPLE v. CONRADO LAOG Y RAMIN

VILLARAMA, JR., J.

Appellant principally attacks the credibility of prosecution witness AAA. Jurisprudence has decreed that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts"[24]and "absent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[25]This rule is even more stringently applied if the appellate court concurred with the trial court.[26]

GR No. 182550

2011-03-23

PEOPLE v. RUEL VELARDE

BRION, J.

We affirm the awards made by the lower courts of civil indemnity in the amount of P50,000.00 and moral damages in the amount of P50,000.00, which are amounts in accordance with the latest jurisprudence on rape. Civil indemnity is mandatory when rape is found to have been committed.[34] Moral damages are awarded to rape victims without need of proof other than the fact of rape, on the assumption that the victim suffered moral injuries from the experience she underwent.[35]

GR No. 184922

2011-02-23

PEOPLE v. PORFERIO MASAGCA

BRION, J.

We, likewise, affirm the award of moral damages made by the trial court for each count of rape. Moral damages are awarded to rape victims without need of proof other than the fact of rape, on the assumption that the victim suffered moral injuries from the experience she underwent.[25] We, however, increase the award of P50,000.00 to P75,000.00 based on the prevailing jurisprudence on the award of moral damages in cases of qualified rape.[26]

GR No. 180914

2010-11-24

PEOPLE v. DOMINGO DOMINGUEZ

LEONARDO-DE CASTRO, J.

Jurisprudence has decreed that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts"[45] and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[46] This rule is even more stringently applied if the appellate court concurred with the trial court.

GR No. 186533

2010-08-09

PEOPLE v. EFREN CASTILLO

PEREZ, J.

In sum, AAA's straightforward testimony, as well as her unwavering and positive identification of the appellant as her defiler and tormentor, corroborated by the medical findings conducted by Dr. Antillon-Malimas, was sufficient to convict the appellant. The flimsy and self-serving defenses of denial and alibi of the appellant failed to destroy the truthfulness and the credibility of AAA's testimony.[52]

GR No. 177295

2010-01-06

PEOPLE v. MARLON BARSAGA ABELLA

LEONARDO-DE CASTRO, J.

By well-entrenched jurisprudence, the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts" and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[26] In People v. Santos,[27] this policy has been emphasized as follows: We stress the well-settled doctrine that the lower court's assessment of the credibility of a witness is accorded great respect owing to its direct opportunity to observe the latter's demeanor during trial. In People v. Ayuda, we held:

GR No. 172372

2009-12-04

PEOPLE v. ROMAR TEODORO Y VALLEJO

BRION, J.

The award of moral damages also finds full justification in this case. Moral damages are awarded to rape victims without need of proof other than the fact of rape on the assumption that the victim suffered moral injuries from the experience she underwent.[44] Pursuant to current rules, we award P50,000.00 as moral damages to AAA.[45]

GR No. 171313

2009-08-16

PEOPLE v. EDGAR TRAYCO Y MASOLA

BRION, J.

Similarly, moral damages are awarded to rape victims without need of proof other than the fact of rape under the assumption that the victim suffered moral injuries from the experience she underwent.[41] Pursuant to current rules, we affirm the award of P50,000.00 as moral damages to AAA.[42]

GR No. 182454

2009-07-23

PEOPLE v. FELIX WASIT

VELASCO JR., J.

We, thus, affirm the trial court's assessment of the testimonial evidence. First, the evaluation of the witnesses' credibility is, to repeat, a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings, unless it overlooked or misconstrued some facts of substance which could have affected the outcome of the case.[18] This rule finds an even more stringent application where the appellate court sustains the trial court's factual determination,[19] as here.

GR No. 170235

2009-04-24

PEOPLE v. JAIME CADAG JIMENEZ

LEONARDO-DE CASTRO, J.

It is elementary that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts" and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case." [26] This Court even recognizes a more stringent application of the rule if the said findings of the trial court are sustained by the appellate court.

GR No. 177151

2008-08-22

PEOPLE v. ARIEL JACOB Y ZUÑEGA

BRION, J.

Moral damages are awarded to rape victims without need of proof other than the fact of rape under the assumption that the victim suffered moral injuries from the experience she underwent. This award is separate and distinct from the awarded civil indemnity.[51] In light of current jurisprudence that pegs the award at P50,000.00, we increase the lower court's award of P30,000.00 to P50,000.00.

	GR No. 208760 2014-04-23	PEOPLE v. FLORO BUBAN BARCELA MENDOZA, J.
Jurisprudence is replete with cases where the Court ruled that questions on the credibility of witnesses should best be addressed to the trial court because of its unique position to observe that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which is denied to the appellate courts.[12] The trial judge has the advantage of actually examining both real and testimonial evidence including the demeanor of the witnesses. Hence, the judge's assessment of the witnesses' testimonies and findings of fact are accorded great respect on appeal. In the absence of any substantial reason to justify the reversal of the trial court's assessment and conclusion, as when no significant facts and circumstances are shown to have been overlooked or disregarded, the reviewing court is generally bound by the former's findings.[13] The rule is even more stringently applied if the appellate court has concurred with the trial court.
	GR No. 192239 2013-06-05	PEOPLE v. RICARDO PAMINTUAN Y SAHAGUN LEONARDO-DE CASTRO, J.
The accused-appellant's bare denial of the crime charged is insufficient to exculpate him. Well established is the rule that "a mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crimes attributed to him."[30] The Court also finds unconvincing the reason ascribed by accused-appellant on the part of AAA to accuse him of rape, i.e., that AAA and her siblings disapproved of him as their mother's common-law husband. We find this argument flimsy and totally bereft of any corroboration. We already ruled that "[m]otives such as resentment, hatred, or revenge have never swayed this Court from giving full credence to the testimony of a minor rape victim. Further, ill motives become inconsequential if the rape victim gave an affirmative and credible declaration, which clearly established the liability of the accused."[31]
	GR No. 186499 2012-03-21	PEOPLE v. MELECIO DE LOS SANTOS LEONARDO-DE CASTRO, J.
The defense of denial on the part of the accused-appellant cannot likewise exculpate him in the case at bar. The accused-appellant testified that on the afternoon of February 14, 1995, the accused-appellant claimed that he was at their house in Escalante, Negros attending to his sick father Melecio de los Santos, Sr. He even alleged that his father died on February 20, 1995. He further stated that he did not go back to XXX in the year 1995. He contended that the last time he went to the house of AAA was on September 2, 1997 when he informed them of his impending marriage. He stated that he indeed got married on September 10, 1997. The Court notes that the above testimony of the accused-appellant was without any substantial corroboration. The death certificate of Melecio de los Santos, Sr. and the marriage certificate of the accused-appellant, which were offered in evidence to support the accused-appellant's claims, were not squarely in point. The said certificates evidenced only the fact of death of Melecio de los Santos, Sr. and the fact of marriage of the accused-appellant, respectively, and in no way proved with certainty the whereabouts of the accused-appellant on the date the incident of rape was committed. In People v. Nieto,[54] we stressed that "[i]t is an established jurisprudential rule that a mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crimes attributed to him."[55] The accused- appellant likewise failed to impute any ill motive on the part of the prosecution witnesses that would have impelled them to prevaricate and charge him falsely.
	GR No. 181497 2012-02-22	PEOPLE v. PATERNO SARMIENTO SAMANDRE LEONARDO-DE CASTRO, J.
The issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts"[34] and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[35] The Court of Appeals further affirmed the findings of the RTC. In this regard, it is settled that when the findings of the trial court have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court. [36] The Court finds no compelling reason herein to deviate from said findings.
	GR No. 182412 2011-11-28	PEOPLE v. PROMULGATED: JOJO DELA PAZ Y TABOCAN BRION, J.
We likewise affirm the CA's award of moral damages in the amount of P50,000.00. Moral damages are awarded to rape victims without need of proof other than the fact of rape, as the victim suffered moral injuries from the experience she underwent.[27]
	GR No. 178321 2011-10-05	PEOPLE v. CONRADO LAOG Y RAMIN VILLARAMA, JR., J.
Appellant principally attacks the credibility of prosecution witness AAA. Jurisprudence has decreed that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts"[24]and "absent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[25]This rule is even more stringently applied if the appellate court concurred with the trial court.[26]
	GR No. 182550 2011-03-23	PEOPLE v. RUEL VELARDE BRION, J.
We affirm the awards made by the lower courts of civil indemnity in the amount of P50,000.00 and moral damages in the amount of P50,000.00, which are amounts in accordance with the latest jurisprudence on rape. Civil indemnity is mandatory when rape is found to have been committed.[34] Moral damages are awarded to rape victims without need of proof other than the fact of rape, on the assumption that the victim suffered moral injuries from the experience she underwent.[35]
	GR No. 184922 2011-02-23	PEOPLE v. PORFERIO MASAGCA BRION, J.
We, likewise, affirm the award of moral damages made by the trial court for each count of rape. Moral damages are awarded to rape victims without need of proof other than the fact of rape, on the assumption that the victim suffered moral injuries from the experience she underwent.[25] We, however, increase the award of P50,000.00 to P75,000.00 based on the prevailing jurisprudence on the award of moral damages in cases of qualified rape.[26]
	GR No. 180914 2010-11-24	PEOPLE v. DOMINGO DOMINGUEZ LEONARDO-DE CASTRO, J.
Jurisprudence has decreed that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts"[45] and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[46] This rule is even more stringently applied if the appellate court concurred with the trial court.
	GR No. 186533 2010-08-09	PEOPLE v. EFREN CASTILLO PEREZ, J.
In sum, AAA's straightforward testimony, as well as her unwavering and positive identification of the appellant as her defiler and tormentor, corroborated by the medical findings conducted by Dr. Antillon-Malimas, was sufficient to convict the appellant. The flimsy and self-serving defenses of denial and alibi of the appellant failed to destroy the truthfulness and the credibility of AAA's testimony.[52]
	GR No. 177295 2010-01-06	PEOPLE v. MARLON BARSAGA ABELLA LEONARDO-DE CASTRO, J.
By well-entrenched jurisprudence, the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying which opportunity is denied to the appellate courts" and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case."[26] In People v. Santos,[27] this policy has been emphasized as follows: We stress the well-settled doctrine that the lower court's assessment of the credibility of a witness is accorded great respect owing to its direct opportunity to observe the latter's demeanor during trial. In People v. Ayuda, we held:
	GR No. 172372 2009-12-04	PEOPLE v. ROMAR TEODORO Y VALLEJO BRION, J.
The award of moral damages also finds full justification in this case. Moral damages are awarded to rape victims without need of proof other than the fact of rape on the assumption that the victim suffered moral injuries from the experience she underwent.[44] Pursuant to current rules, we award P50,000.00 as moral damages to AAA.[45]
	GR No. 171313 2009-08-16	PEOPLE v. EDGAR TRAYCO Y MASOLA BRION, J.
Similarly, moral damages are awarded to rape victims without need of proof other than the fact of rape under the assumption that the victim suffered moral injuries from the experience she underwent.[41] Pursuant to current rules, we affirm the award of P50,000.00 as moral damages to AAA.[42]
	GR No. 182454 2009-07-23	PEOPLE v. FELIX WASIT VELASCO JR., J.
We, thus, affirm the trial court's assessment of the testimonial evidence. First, the evaluation of the witnesses' credibility is, to repeat, a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings, unless it overlooked or misconstrued some facts of substance which could have affected the outcome of the case.[18] This rule finds an even more stringent application where the appellate court sustains the trial court's factual determination,[19] as here.
	GR No. 170235 2009-04-24	PEOPLE v. JAIME CADAG JIMENEZ LEONARDO-DE CASTRO, J.
It is elementary that the issue of credibility of witnesses is "a question best addressed to the province of the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts" and "[a]bsent any substantial reason which would justify the reversal of the trial court's assessments and conclusions, the reviewing court is generally bound by the former's findings, particularly when no significant facts and circumstances are shown to have been overlooked or disregarded which when considered would have affected the outcome of the case." [26] This Court even recognizes a more stringent application of the rule if the said findings of the trial court are sustained by the appellate court.
	GR No. 177151 2008-08-22	PEOPLE v. ARIEL JACOB Y ZUÑEGA BRION, J.
Moral damages are awarded to rape victims without need of proof other than the fact of rape under the assumption that the victim suffered moral injuries from the experience she underwent. This award is separate and distinct from the awarded civil indemnity.[51] In light of current jurisprudence that pegs the award at P50,000.00, we increase the lower court's award of P30,000.00 to P50,000.00.

PEOPLE v. SALVADOR NIETO y CABALSE