Lawyerly

GR No. 211049

2014-08-06

REYES, J.

Rape is committed in secrecy, and often it is only the victim who can testify as to the fact of the forced coitus.[17] AAA's sole testimony is sufficient to produce conviction.[18] When a woman says she was raped, she says in effect all that is necessary to show that a rape was committed, and if her testimony meets the test of credibility, conviction may issue on the basis thereof.[19] This holds true with greater force when the woman is the minor daughter of the accused-appellant, and no motive has been shown why she would concoct such a sordid charge against her own father, unless it is true.[20]

GR No. 185716

2010-09-29

PEOPLE v. MIGUELITO MALANA Y LARDISABAY

PEREZ, J.

Accused-appellant's defense that private complainant and her mother were harboring a personal grudge against him, fails in light of the positive and straightforward testimony of private complainant identifying accused-appellant as the one who had raped and ravished her. This is bolstered by the fact that it is unnatural for a parent to use his offspring as an engine of malice.[34] Verily, the testimony of the rape victim against her father, in this particular case, is entitled to greater weight, since reverence and respect for elders is too deeply ingrained in Filipino children and is even recognized by law.[35] Finally, a daughter would not accuse her own father of a serious offense like rape had she not really been aggrieved.[36]

GR No. 180925

2008-08-20

PEOPLE v. JAIME DEL CASTILLO

TINGA, J,

In a prosecution for rape, the victim's credibility becomes the single most important issue. For, when a woman says she was raped, she says in effect all that is necessary to show that rape was committed; thus, if her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[20] In this case, the test of credibility of the rape victim was more than sufficiently met.

GR No. 175275

2008-02-19

EMILIO CAMPOS v. PEOPLE

YNARES-SATIAGO, J.

Indeed, it takes extraordinary courage in a child to break her silence and expose herself and her family to the stigma that incestuous rape brings. The fact that AAA braved the grueling trial to prosecute her father speaks volumes of the truth of her assertions. In People v. Capareda,[28] we held:Established is the rule that the testimonies of rape victims, especially child victims, are given full weight and credit. It bears emphasis that the victim was barely thirteen when she was raped. In a litany of cases, this Court has applied the well-settled rule that when a woman, more so if she is a minor, says that she has been raped, she says, in effect, all that is necessary to prove that rape was committed, for as long as her testimony meets the test of credibility. No young girl, indeed, would concoct a sordid tale of so serious a crime as rape at the hands of a close kin, undergo medical examination, then subject herself to the stigma and embarrassment of a public trial, if her motive were other than an earnest desire to seek justice. This holds true especially where the complainant is a minor, whose testimony deserves full credence.[29]

GR No. 177565

2008-01-28

PEOPLE v. ELMER GLIVANO y SILVALLANA

NACHURA, J.

The delay in the reporting of the crime, the absence of a threat on the life of the victim, and the presence of other occupants in the house cannot weaken the force of the victim's clear and convincing statements. Jurisprudence states that the delay in reporting the commission of rape is not an indication of a fabricated charge. The charge is beclouded - only if the delay is unreasonable and unexplained.[27] Often, victims would rather bear the ignominy and the pain in private than reveal their shame to the world.[28] Likewise, a stepfather, who exercises moral and physical ascendancy over his stepdaughter, need not make any threat against her because the latter is cowed into submission when gripped with the fear of refusing the advances of a person she customarily obeys.[29] Rape may, likewise, be committed in a room adjacent to where the victim's family is sleeping, or even in a room shared with other people. There is no rule that rape can only be committed in seclusion.[30]

GR No. 176633

2007-09-05

PEOPLE v. ARMANDO SAN ANTONIO

CHICO-NAZARIO, J.

Case law has it that the failure of the victim to shout or offer tenacious resistance does not make voluntary the victim's submission to the criminal acts of the accused.[33] Not all rape victims can be expected to act conformably to the usual expectations of everyone. Different and varying degrees of behavioral responses are expected in the proximity of, or in confronting, an aberrant episode. It is well-settled that different people react differently to a given situation or type of situation.[34] There is no standard form of reaction for a woman, much more a minor, when facing a shocking and horrifying experience such as a sexual assault. The workings of the human mind placed under emotional stress are unpredictable, and people react differently - some may shout, some may faint, and some may be shocked into insensibility while others may openly welcome the intrusion.[35] In the present case, it is noteworthy that at the time the complainant was raped, she was only 14 years old,[36] while the appellant was already 23 years old, thus, her failure to shout could be attributed to the shock and horror which she felt as a result of appellant's sexual assault.

GR NO. 174199

2007-03-07

PEOPLE v. ROGELIO ALARCON Y TIOXON APPELLANT

TINGA, J.

AAA's testimony categorically established the fact of her defloration at the hands of her father at that. Indeed, she positively identified appellant as the perpetrator of the crime. She was only ten (10) years old when the rape was committed. It is inconceivable for a child to concoct a sordid tale of so serious a crime as rape at the hands of a close kin, her father in this case, and subject herself to the stigma and embarrassment of a public trial, if her motive were other than an earnest desire to seek justice.[25] Thus, it becomes implausible for AAA to make up the rape story over her resentment caused by her father's beatings.

GR NO. 168649

2006-12-06

PEOPLE v. JOSE ALVIZO AUDINE

CHICO-NAZARIO, J.

In the review of rape cases, we are almost invariably guided by the following principles: (1) an accusation of rape can be made with facility; it is difficult to prove but more difficult for the accused, though innocent, to disprove; (2) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) 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 for the defense.[20]

GR NO. 172322

2006-09-08

PEOPLE v. RENE SANTOS

TINGA, J.

The contention is neither novel nor persuasive. There is no standard form of behavior that can be expected of rape victims after they have been defiled because people react differently to emotional stress.[44] Nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal.[45] Certainly, it is difficult to predict in every instance how a person - especially a 6-year old child, as in this case - would react to a traumatic experience.[46] It is not proper to judge the actions of rape victims, especially children, who have undergone the harrowing experience of being ravished against their will by the norms of behavior expected under such circumstances from mature persons.[47] Indeed, the range of emotions shown by rape victims is yet to be captured even by calculus.[48] It is thus unrealistic to expect uniform reactions from them.[49] In fact, the Court has not laid down any rule on how a rape victim should behave immediately after her ravishment.[50]

GR NO. 170191

2006-08-16

PEOPLE v. RODOLFO SUYU

CALLEJO, SR., J.

Understandably, Clarissa was reluctant to reveal, while at the police station, the fact that she was raped, considering that her boyfriend was present when she. made her first statement before the police investigator. Further, one of the investigating officers was her townmate. Indeed, the fear of social humiliation prevented Clarissa from revealing, at the time, the details of her defilement. She was in a state of trauma, impelled by her natural instinct to put out of her mind such a painful and disturbing experience. Oftentimes, victims would rather bear the ignominy and the pain in private than reveal their shame to the world.[65] In her desire for justice, she, nonetheless, later revealed the true events that happened on that fateful night of January 13, 1996, thus: Pros. Sagucio: Q:

	GR No. 211049 2014-08-06	PEOPLE v. ROMEO CLOSA Y LUALHATI REYES, J.
Rape is committed in secrecy, and often it is only the victim who can testify as to the fact of the forced coitus.[17] AAA's sole testimony is sufficient to produce conviction.[18] When a woman says she was raped, she says in effect all that is necessary to show that a rape was committed, and if her testimony meets the test of credibility, conviction may issue on the basis thereof.[19] This holds true with greater force when the woman is the minor daughter of the accused-appellant, and no motive has been shown why she would concoct such a sordid charge against her own father, unless it is true.[20]
	GR No. 185716 2010-09-29	PEOPLE v. MIGUELITO MALANA Y LARDISABAY PEREZ, J.
Accused-appellant's defense that private complainant and her mother were harboring a personal grudge against him, fails in light of the positive and straightforward testimony of private complainant identifying accused-appellant as the one who had raped and ravished her. This is bolstered by the fact that it is unnatural for a parent to use his offspring as an engine of malice.[34] Verily, the testimony of the rape victim against her father, in this particular case, is entitled to greater weight, since reverence and respect for elders is too deeply ingrained in Filipino children and is even recognized by law.[35] Finally, a daughter would not accuse her own father of a serious offense like rape had she not really been aggrieved.[36]
	GR No. 180925 2008-08-20	PEOPLE v. JAIME DEL CASTILLO TINGA, J,
In a prosecution for rape, the victim's credibility becomes the single most important issue. For, when a woman says she was raped, she says in effect all that is necessary to show that rape was committed; thus, if her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[20] In this case, the test of credibility of the rape victim was more than sufficiently met.
	GR No. 175275 2008-02-19	EMILIO CAMPOS v. PEOPLE YNARES-SATIAGO, J.
Indeed, it takes extraordinary courage in a child to break her silence and expose herself and her family to the stigma that incestuous rape brings. The fact that AAA braved the grueling trial to prosecute her father speaks volumes of the truth of her assertions. In People v. Capareda,[28] we held:Established is the rule that the testimonies of rape victims, especially child victims, are given full weight and credit. It bears emphasis that the victim was barely thirteen when she was raped. In a litany of cases, this Court has applied the well-settled rule that when a woman, more so if she is a minor, says that she has been raped, she says, in effect, all that is necessary to prove that rape was committed, for as long as her testimony meets the test of credibility. No young girl, indeed, would concoct a sordid tale of so serious a crime as rape at the hands of a close kin, undergo medical examination, then subject herself to the stigma and embarrassment of a public trial, if her motive were other than an earnest desire to seek justice. This holds true especially where the complainant is a minor, whose testimony deserves full credence.[29]
	GR No. 177565 2008-01-28	PEOPLE v. ELMER GLIVANO y SILVALLANA NACHURA, J.
The delay in the reporting of the crime, the absence of a threat on the life of the victim, and the presence of other occupants in the house cannot weaken the force of the victim's clear and convincing statements. Jurisprudence states that the delay in reporting the commission of rape is not an indication of a fabricated charge. The charge is beclouded - only if the delay is unreasonable and unexplained.[27] Often, victims would rather bear the ignominy and the pain in private than reveal their shame to the world.[28] Likewise, a stepfather, who exercises moral and physical ascendancy over his stepdaughter, need not make any threat against her because the latter is cowed into submission when gripped with the fear of refusing the advances of a person she customarily obeys.[29] Rape may, likewise, be committed in a room adjacent to where the victim's family is sleeping, or even in a room shared with other people. There is no rule that rape can only be committed in seclusion.[30]
	GR No. 176633 2007-09-05	PEOPLE v. ARMANDO SAN ANTONIO CHICO-NAZARIO, J.
Case law has it that the failure of the victim to shout or offer tenacious resistance does not make voluntary the victim's submission to the criminal acts of the accused.[33] Not all rape victims can be expected to act conformably to the usual expectations of everyone. Different and varying degrees of behavioral responses are expected in the proximity of, or in confronting, an aberrant episode. It is well-settled that different people react differently to a given situation or type of situation.[34] There is no standard form of reaction for a woman, much more a minor, when facing a shocking and horrifying experience such as a sexual assault. The workings of the human mind placed under emotional stress are unpredictable, and people react differently - some may shout, some may faint, and some may be shocked into insensibility while others may openly welcome the intrusion.[35] In the present case, it is noteworthy that at the time the complainant was raped, she was only 14 years old,[36] while the appellant was already 23 years old, thus, her failure to shout could be attributed to the shock and horror which she felt as a result of appellant's sexual assault.
	GR NO. 174199 2007-03-07	PEOPLE v. ROGELIO ALARCON Y TIOXON APPELLANT TINGA, J.
AAA's testimony categorically established the fact of her defloration at the hands of her father at that. Indeed, she positively identified appellant as the perpetrator of the crime. She was only ten (10) years old when the rape was committed. It is inconceivable for a child to concoct a sordid tale of so serious a crime as rape at the hands of a close kin, her father in this case, and subject herself to the stigma and embarrassment of a public trial, if her motive were other than an earnest desire to seek justice.[25] Thus, it becomes implausible for AAA to make up the rape story over her resentment caused by her father's beatings.
	GR NO. 168649 2006-12-06	PEOPLE v. JOSE ALVIZO AUDINE CHICO-NAZARIO, J.
In the review of rape cases, we are almost invariably guided by the following principles: (1) an accusation of rape can be made with facility; it is difficult to prove but more difficult for the accused, though innocent, to disprove; (2) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) 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 for the defense.[20]
	GR NO. 172322 2006-09-08	PEOPLE v. RENE SANTOS TINGA, J.
The contention is neither novel nor persuasive. There is no standard form of behavior that can be expected of rape victims after they have been defiled because people react differently to emotional stress.[44] Nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal.[45] Certainly, it is difficult to predict in every instance how a person - especially a 6-year old child, as in this case - would react to a traumatic experience.[46] It is not proper to judge the actions of rape victims, especially children, who have undergone the harrowing experience of being ravished against their will by the norms of behavior expected under such circumstances from mature persons.[47] Indeed, the range of emotions shown by rape victims is yet to be captured even by calculus.[48] It is thus unrealistic to expect uniform reactions from them.[49] In fact, the Court has not laid down any rule on how a rape victim should behave immediately after her ravishment.[50]
	GR NO. 170191 2006-08-16	PEOPLE v. RODOLFO SUYU CALLEJO, SR., J.
Understandably, Clarissa was reluctant to reveal, while at the police station, the fact that she was raped, considering that her boyfriend was present when she. made her first statement before the police investigator. Further, one of the investigating officers was her townmate. Indeed, the fear of social humiliation prevented Clarissa from revealing, at the time, the details of her defilement. She was in a state of trauma, impelled by her natural instinct to put out of her mind such a painful and disturbing experience. Oftentimes, victims would rather bear the ignominy and the pain in private than reveal their shame to the world.[65] In her desire for justice, she, nonetheless, later revealed the true events that happened on that fateful night of January 13, 1996, thus: Pros. Sagucio: Q:

PEOPLE v. EMILIANO CAPAREDA