Lawyerly

GR No. 183097

2012-09-12

DEL CASTILLO, J.

In the appreciation of the evidence for the prosecution and the defense, the settled rule is that the assessment of the credibility of witnesses is left largely to the trial court. And in almost all rape cases, the credibility of the victim's testimony is crucial in view of the intrinsic nature of the crime where only the participants therein can testify to its occurrence. "[The victim's] testimony is most vital and must be received with the utmost caution."[9] Once found credible, the victim's lone testimony is sufficient to sustain a conviction.[10] Absent therefore any substantial reason to justify the reversal of the assessments and conclusions of the trial court especially if such findings have been affirmed by the appellate court, the evaluation of the credibility of witnesses is well-nigh conclusive to this Court.

GR No. 166566

2010-11-23

PEOPLE v. WENCESLAO DERI y BENITEZ

MENDOZA, J.

In essence, the crime of rape is typically committed in relative isolation or even secrecy, thus, normally it is only the victim who can testify on the circumstances surrounding the forced coitus.[49] Therefore, in the prosecution of rape, the credibility of the rape victim is usually the single most important issue to determine.[50] Should her testimony withstand the test of credibility, the victim's account would be adequate to sustain a conviction.[51]

GR No. 186379

2009-08-19

PEOPLE v. BIENVENIDO LAZARO

CHICO-NAZARIO, J.

Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[15] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[16] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[17]

GR No. 185389

2009-07-07

PEOPLE v. BENJIE RESURRECCION

CHICO-NAZARIO, J.

Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[14] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[15] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[16]

GR No. 184598

2009-06-23

PEOPLE v. JULIO MANALILI

CHICO-NAZARIO, J.

Since the crime of rape is essentially one committed in relative isolation or even secrecy, hence it is usually only the victim who can testify with regard to the fact of the forced coitus.[23] In the prosecution of rape, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[24] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[25]

GR No. 185380

2009-06-18

PEOPLE v. ROGELIO MARCOS

CHICO-NAZARIO, J.

Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[14] In a prosecution for rape, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[15] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[16]

GR No. 172470

2008-04-08

PEOPLE v. SAMMY RAMOS Y DALERE

CHICO-NAZARIO, J.

Since the crime of rape is essentially one committed in relative isolation or even secrecy, hence, it is usually only the victim who can testify with regard to the fact of the forced coitus.[33] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[34] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[35]

GR No. 139229

2002-04-22

PEOPLE v. ESMERALDO CANA Y DEL VALLE

QUISUMBING, J.

A: I was taught. COURT: The Court take (sic) notice that in Grade I you will not learn how to read and write fully. That is of judicial notice.[63] Nevertheless, after careful reading of the records, we find that even if the alleged leading questions were not allowed, Jovelyn's testimony appears credible and comprehensive. She gave a candid, plain, and straightforward account on how she was raped by appellant. She spoke in a manner reflective of honest and unrehearsed testimony. Moreover, when it comes to the issue of credibility, this Court generally defers to the assessment and evaluation given by the trial court[64] because of its unique position to observe the demeanor of the witnesses. In this case, we reiterate the truism that it is highly inconceivable that a young barrio lass, inexperienced with the ways of the world, would fabricate a charge of defloration, undergo a medical examination of her private parts, subject herself to public trial, and tarnish her family's honor and reputation, unless she was motivated by a potent desire to seek justice for the wrong committed against her.[65]

GR Nos. 136867-68

2001-09-24

PEOPLE v. RODRIGO GALVEZ Y JEREZ

YNARES-SANTIAGO, J.

The Court has ruled that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[20] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[21]

GR No. 132714

2001-09-06

PEOPLE v. RENATO LALINGJAMAN

YNARES-SANTIAGO, J.

Owing to the severity of the penalty imposed, the Court, in reviewing this case must be guided by the following principles: a.) an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime; b.) in view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must be always be scrutinized with extreme caution; and c.) the evidence for the prosecution must stand or fall on its own merits and cannot be allowed to draw strength from the weakness of the evidence of the defense.[10] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[11]

GR No. 137282

2001-03-16

PEOPLE v. ALFREDO ALIPAR Y ALINSOD

DE LEON, JR., J.

Accused-appellant's assault on the credibility of Twinkle stands on tenuous grounds. When faced with the issue of credibility of the witnesses, this Court ordinarily defers to the factual assessment made by the trial court for the latter is in a better position to decide the question, having heard the witnesses and observed their deportment and manner of testifying on the witness stand. Absent any showing that such assessment is tainted with arbitrariness or oversight of some fact or circumstance of weight and influence, this Court will not depart from the factual conclusions of the trial court.[25] That is the jurisprudential rule. None appears in the record of the case at bar to warrant departure from the said rule.

GR Nos. 133586-603

2001-02-19

PEOPLE v. HENRY QUEIGAN

YNARES-SANTIAGO, J.

Witness Inday Nelly Deles corroborated the testimonies of the defense witness except for the fact that according to her, she gave the accused P10,000.00 and instructed one of her helpers to secure the funeral service. After the burial of the wife of the accused, he went back to his work in Antipolo, Rizal. It was only after September 14, 1996 when she failed to return back to his work in Antipolo, Rizal. The Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[15] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[16]

GR No. 137696

2001-01-24

PEOPLE v. EDDIE SERNADILLA

PER CURIAM

With respect to accused-appellant's first argument in his appellant's brief, we note the well-established rule that the trial court's evaluation of the credibility of witnesses is given great respect by the appellate court in the absence of proof that it was arrived at capriciously or that the trial court disregarded material facts which might affect the outcome of the case.[8] The rationale behind this rule is that the credibility of a witness can best be determined by the trial court since it is in a position to observe the candor and demeanor of the witnesses.[9] It is only the trial court which has the unique opportunity to observe the elusive and incommunicable evidence of the witness's deportment on the witness stand while testifying, an opportunity denied to the appellate courts which usually rely on the silent records of the case[10]

GR No. 130406

2001-01-22

PEOPLE v. RUEL BAWAY Y ALIGAN

YNARES-SANTIAGO, J.

4.] In fact, the bulk of the evidence shows that force, if any, was employed not before or during the alleged rape, but after, and thus makes the claim that she was forced to submit to sexual intercourse rather incredible. In reviewing rape cases, the Court will be guided by the principle that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[15] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[16]

GR Nos. 137408-10

2000-12-08

PEOPLE v. WILLY MARQUEZ

YNARES-SANTIAGO, J.

The Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[25] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[26]

GR Nos. 135511-13

2000-11-17

PEOPLE v. ENRICO MARIANO

PER CURIAM

Time and again this Court has held that when it comes to the issue of credibility, this Court ordinarily defers to the assessment and evaluation given by the trial court for only the trial court has the unique opportunity to observe that elusive and incommunicble evidence of the witness' deportment on the witness stand while testifying, an opportunity denied to the appellate courts which usually rely on the cold pages of the silent records of the case.[37] Only when such assessment is tainted with arbitrariness or oversight of some fact or circumstance of weight and influence will the appellate court depart from the trial court's factual conclusions.[38] None appears in the subject Criminal Cases Nos. 10343-SP, 10344-SP and 10345-SP.

GR No. 131942

2000-10-05

PEOPLE v. CARLITO BAWANG

YNARES-SANTIAGO, J.

This Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape may be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the felony. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[24] Thus in a prosecution for rape, the complainant's credibility becomes the single most important issue.[25]

	GR No. 183097 2012-09-12	PEOPLE v. ANTONINO VENTURINA DEL CASTILLO, J.
In the appreciation of the evidence for the prosecution and the defense, the settled rule is that the assessment of the credibility of witnesses is left largely to the trial court. And in almost all rape cases, the credibility of the victim's testimony is crucial in view of the intrinsic nature of the crime where only the participants therein can testify to its occurrence. "[The victim's] testimony is most vital and must be received with the utmost caution."[9] Once found credible, the victim's lone testimony is sufficient to sustain a conviction.[10] Absent therefore any substantial reason to justify the reversal of the assessments and conclusions of the trial court especially if such findings have been affirmed by the appellate court, the evaluation of the credibility of witnesses is well-nigh conclusive to this Court.
	GR No. 166566 2010-11-23	PEOPLE v. WENCESLAO DERI y BENITEZ MENDOZA, J.
In essence, the crime of rape is typically committed in relative isolation or even secrecy, thus, normally it is only the victim who can testify on the circumstances surrounding the forced coitus.[49] Therefore, in the prosecution of rape, the credibility of the rape victim is usually the single most important issue to determine.[50] Should her testimony withstand the test of credibility, the victim's account would be adequate to sustain a conviction.[51]
	GR No. 186379 2009-08-19	PEOPLE v. BIENVENIDO LAZARO CHICO-NAZARIO, J.
Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[15] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[16] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[17]
	GR No. 185389 2009-07-07	PEOPLE v. BENJIE RESURRECCION CHICO-NAZARIO, J.
Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[14] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[15] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[16]
	GR No. 184598 2009-06-23	PEOPLE v. JULIO MANALILI CHICO-NAZARIO, J.
Since the crime of rape is essentially one committed in relative isolation or even secrecy, hence it is usually only the victim who can testify with regard to the fact of the forced coitus.[23] In the prosecution of rape, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[24] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[25]
	GR No. 185380 2009-06-18	PEOPLE v. ROGELIO MARCOS CHICO-NAZARIO, J.
Since the crime of rape is essentially one committed in relative isolation or even secrecy, it is usually only the victim who can testify with regard to the fact of the forced coitus.[14] In a prosecution for rape, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[15] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[16]
	GR No. 172470 2008-04-08	PEOPLE v. SAMMY RAMOS Y DALERE CHICO-NAZARIO, J.
Since the crime of rape is essentially one committed in relative isolation or even secrecy, hence, it is usually only the victim who can testify with regard to the fact of the forced coitus.[33] In its prosecution, therefore, the credibility of the victim is almost always the single and most important issue to deal with.[34] If her testimony meets the test of credibility, the accused can justifiably be convicted on the basis thereof; otherwise, he should be acquitted of the crime.[35]
	GR No. 139229 2002-04-22	PEOPLE v. ESMERALDO CANA Y DEL VALLE QUISUMBING, J.
A: I was taught. COURT: The Court take (sic) notice that in Grade I you will not learn how to read and write fully. That is of judicial notice.[63] Nevertheless, after careful reading of the records, we find that even if the alleged leading questions were not allowed, Jovelyn's testimony appears credible and comprehensive. She gave a candid, plain, and straightforward account on how she was raped by appellant. She spoke in a manner reflective of honest and unrehearsed testimony. Moreover, when it comes to the issue of credibility, this Court generally defers to the assessment and evaluation given by the trial court[64] because of its unique position to observe the demeanor of the witnesses. In this case, we reiterate the truism that it is highly inconceivable that a young barrio lass, inexperienced with the ways of the world, would fabricate a charge of defloration, undergo a medical examination of her private parts, subject herself to public trial, and tarnish her family's honor and reputation, unless she was motivated by a potent desire to seek justice for the wrong committed against her.[65]
	GR Nos. 136867-68 2001-09-24	PEOPLE v. RODRIGO GALVEZ Y JEREZ YNARES-SANTIAGO, J.
The Court has ruled that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[20] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[21]
	GR No. 132714 2001-09-06	PEOPLE v. RENATO LALINGJAMAN YNARES-SANTIAGO, J.
Owing to the severity of the penalty imposed, the Court, in reviewing this case must be guided by the following principles: a.) an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime; b.) in view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must be always be scrutinized with extreme caution; and c.) the evidence for the prosecution must stand or fall on its own merits and cannot be allowed to draw strength from the weakness of the evidence of the defense.[10] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[11]
	GR No. 137282 2001-03-16	PEOPLE v. ALFREDO ALIPAR Y ALINSOD DE LEON, JR., J.
Accused-appellant's assault on the credibility of Twinkle stands on tenuous grounds. When faced with the issue of credibility of the witnesses, this Court ordinarily defers to the factual assessment made by the trial court for the latter is in a better position to decide the question, having heard the witnesses and observed their deportment and manner of testifying on the witness stand. Absent any showing that such assessment is tainted with arbitrariness or oversight of some fact or circumstance of weight and influence, this Court will not depart from the factual conclusions of the trial court.[25] That is the jurisprudential rule. None appears in the record of the case at bar to warrant departure from the said rule.
	GR Nos. 133586-603 2001-02-19	PEOPLE v. HENRY QUEIGAN YNARES-SANTIAGO, J.
Witness Inday Nelly Deles corroborated the testimonies of the defense witness except for the fact that according to her, she gave the accused P10,000.00 and instructed one of her helpers to secure the funeral service. After the burial of the wife of the accused, he went back to his work in Antipolo, Rizal. It was only after September 14, 1996 when she failed to return back to his work in Antipolo, Rizal. The Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[15] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[16]
	GR No. 137696 2001-01-24	PEOPLE v. EDDIE SERNADILLA PER CURIAM
With respect to accused-appellant's first argument in his appellant's brief, we note the well-established rule that the trial court's evaluation of the credibility of witnesses is given great respect by the appellate court in the absence of proof that it was arrived at capriciously or that the trial court disregarded material facts which might affect the outcome of the case.[8] The rationale behind this rule is that the credibility of a witness can best be determined by the trial court since it is in a position to observe the candor and demeanor of the witnesses.[9] It is only the trial court which has the unique opportunity to observe the elusive and incommunicable evidence of the witness's deportment on the witness stand while testifying, an opportunity denied to the appellate courts which usually rely on the silent records of the case[10]
	GR No. 130406 2001-01-22	PEOPLE v. RUEL BAWAY Y ALIGAN YNARES-SANTIAGO, J.
4.] In fact, the bulk of the evidence shows that force, if any, was employed not before or during the alleged rape, but after, and thus makes the claim that she was forced to submit to sexual intercourse rather incredible. In reviewing rape cases, the Court will be guided by the principle that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[15] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[16]
	GR Nos. 137408-10 2000-12-08	PEOPLE v. WILLY MARQUEZ YNARES-SANTIAGO, J.
The Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape can be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the crime. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[25] Thus, in a prosecution for rape, the complainant's credibility becomes the single most important issue.[26]
	GR Nos. 135511-13 2000-11-17	PEOPLE v. ENRICO MARIANO PER CURIAM
Time and again this Court has held that when it comes to the issue of credibility, this Court ordinarily defers to the assessment and evaluation given by the trial court for only the trial court has the unique opportunity to observe that elusive and incommunicble evidence of the witness' deportment on the witness stand while testifying, an opportunity denied to the appellate courts which usually rely on the cold pages of the silent records of the case.[37] Only when such assessment is tainted with arbitrariness or oversight of some fact or circumstance of weight and influence will the appellate court depart from the trial court's factual conclusions.[38] None appears in the subject Criminal Cases Nos. 10343-SP, 10344-SP and 10345-SP.
	GR No. 131942 2000-10-05	PEOPLE v. CARLITO BAWANG YNARES-SANTIAGO, J.
This Court has said time and again that in reviewing rape cases, it will be guided by the settled realities that an accusation for rape may be made with facility. While the commission of the crime may not be easy to prove, it becomes even more difficult for the person accused, although innocent, to disprove that he did not commit the felony. In view of the intrinsic nature of the crime of rape where only two persons are normally involved, the testimony of the complainant must always be scrutinized with great caution.[24] Thus in a prosecution for rape, the complainant's credibility becomes the single most important issue.[25]

PEOPLE v. EMIL BABERA Y RABANERA