Lawyerly

GR No. 217975

2015-11-23

MENDOZA, J.

The Court has held time and again that the testimony of child-victim is normally given full weight and credit considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified was not true.[13] Youth and immaturity are generally badges of truth and sincerity.[14] Hence, there is neither cause nor reason to withhold credence from AAA's testimony.

GR No. 188108

2011-02-21

PEOPLE v. EVILIO MILAGROSA

BRION, J.

We find no reason to disturb the findings of the RTC that the CA wholly affirmed. It is well settled that an accused may be convicted of rape based solely on the testimony of the victim, as long as she is competent and credible. The unique nature of the crime of rape (which is usually committed in a private place where only the perpetrator and the rape victim are present)[7] allows this evidentiary approach and the conclusion the lower courts reached.

GR No. 183577

2010-02-01

PEOPLE v. HILARIO ESCOTON

DEL CASTILLO, J.

Much less convincing is the proposition of the appellant that "AAA" filed the complaint against him because she and her other relatives were harboring ill feelings and evil motives against him. Ill motives become inconsequential where there are affirmative or categorical declarations establishing the accountability of the appellant for the felony, as in this case.[24] Moreover, we have observed that persons convicted of rape sometimes attribute the charges against them to family feuds, resentment or revenge.[25] However, as borne out by numerous cases, family resentment, revenge or feuds have never swayed us from giving full credence to the testimony of a complainant for rape, especially a minor who remained steadfast and unyielding throughout the trial that she was sexually violated.[26]

GR No. 183619

2009-10-13

PEOPLE v. SALVINO SUMINGWA

NACHURA, J.

While appellant's conviction was primarily based on the prosecution's testimonial evidence, the same was corroborated by physical evidence consisting of the medical findings of the medico-legal officer that there were hymenal lacerations. When a rape victim's account is straightforward and candid, and is corroborated by the medical findings of the examining physician, the same is sufficient to support a conviction for rape.[41]

GR No. 185203

2009-09-17

PEOPLE v. DOMINGO ARAOJO

VELASCO JR., J.

As the Court has often repeated, the issue of credibility is a matter best addressed by the trial court which had the chance to observe the demeanor of the witnesses while testifying. For this reason, the Court, as earlier stressed, accords great weight and even finality to factual findings of the trial court, especially its assessments of the witnesses and their credibility, barring arbitrariness or oversight of some fact or circumstance of weight and substance.[15] Testimonies of child-victims are normally given full weight and credit, since when a girl, particularly if she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape has in fact been committed. When the offended party is of tender age and immature, courts are inclined to give credit to her account of what transpired, considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified is not true.[16] Youth and immaturity are generally badges of truth and sincerity.[17]

GR No. 173473

2008-12-17

PEOPLE v. BETH TEMPORADA

YNARES-SANTIAGO, J.

In the instant case, we find no reason to depart from the rule that findings of fact of the trial court on the credibility of witnesses and their testimonies are generally accorded great respect by an appellate court. The assessment of credibility of witnesses is a matter best left to the trial court because it is in the position to observe that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts.[13] Further, there is no showing of any ill-motive on the part of the prosecution witnesses in testifying against appellant. Absent such improper motive, the presumption is that they were not so actuated and their testimony is entitled to full weight and credit.

GR No. 177749

2007-12-17

PEOPLE v. MANUEL AGUILAR

CHICO-NAZARIO, J.

It is well-settled that the appellant may be convicted of rape based solely on the testimony of the victim, as long as the same is competent and credible. This is primarily because the crime of rape is usually committed in a private place where only the aggressor and the rape victim are present.[33] Moreover, even the trial court mentioned in its Decision that even in the absence of the corroborative testimonies of the prosecution's other witnesses, the testimony of AAA can stand on its ground and is enough to convict the appellant.[34]

GR NO. 172118

2007-04-24

PEOPLE v. WARLITO C. FERNANDEZ

CALLEJO, SR., J.

It is also settled that the accused may be convicted solely on the basis of the victim's testimony, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[49] If the victim's testimony meets the test of credibility, this is sufficient to convict the accused. The credibility of the victim is almost always the single most important issue to hurdle.[50]

GR NO. 166401

2006-10-30

PEOPLE v. ALFREDO BON

TINGA, J.

Besides, no sane woman, least of all a child, would concoct a story of defloration, allow an examination of her private parts and subject herself to public trial or ridicule if she has not in truth, been a victim of rape and impelled to seek justice for the wrong done to her. Testimonies of child-victims are normally given full weight and credit, since 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 show that rape has been committed. Youth and immaturity are generally badges of truth and sincerity.[44] The weight of such testimonies may be countered by physical evidence to the contrary, or indubitable proof that the accused could not have committed the rape, but in the absence of such countervailing proof, these testimonies shall be accorded utmost value.

GR NO. 172322

2006-09-08

PEOPLE v. RENE SANTOS

TINGA, J.

The argument is tenuous. As has been pointed out in People v. Guambor:[35]

GR NO. 172322

2006-09-08

PEOPLE v. RENE SANTOS

TINGA, J.

Much less convincing is appellant's proposition that ill feelings and ill motives of the victim's mother impelled the filing of the charges against him. Ill-motives become inconsequential where there are affirmative or categorical declarations establishing appellant's accountability for the felony.[52] We have, furthermore, observed not a few persons convicted of rape have attributed the charges against them to family feuds, resentment or revenge.[53] However, as borne out by a plethora of cases, family resentment, revenge or feuds have never swayed us from giving full credence to the testimony of a complainant for rape, especially a minor who remained steadfast and unyielding throughout the direct and cross- examination that she was sexually abused.[54] It would take a certain degree of perversity on the part of a parent, especially a mother, to concoct a false charge of rape and then use her daughter as an instrument to settle her grudge.[55]

GR NO. 168101

2006-02-13

PEOPLE v. GREGORIO CORPUZ Y ESPIRITU

PER CURIAM

In rape cases, the accused may be convicted solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing and consistent with human nature and the normal course of things.[13]

GR No. 157269

2004-06-03

PEOPLE v. JAIME “JIMBOY” ANTONIO Y MACARIO

YNARES-SATIAGO, J.

The award of moral damages is correct. It is automatically granted in rape cases without need of further proof other than the commission of the crime, because it is assumed that a rape victim has actually suffered moral injuries entitling her to such award. However, it must be reduced from P100,000.00 to P50,000.00 based on prevailing jurisprudence.[19] Moral damages are separate and distinct from civil indemnity.[20]

	GR No. 217975 2015-11-23	PEOPLE v. BERNARDINO BIALA MENDOZA, J.
The Court has held time and again that the testimony of child-victim is normally given full weight and credit considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified was not true.[13] Youth and immaturity are generally badges of truth and sincerity.[14] Hence, there is neither cause nor reason to withhold credence from AAA's testimony.
	GR No. 188108 2011-02-21	PEOPLE v. EVILIO MILAGROSA BRION, J.
We find no reason to disturb the findings of the RTC that the CA wholly affirmed. It is well settled that an accused may be convicted of rape based solely on the testimony of the victim, as long as she is competent and credible. The unique nature of the crime of rape (which is usually committed in a private place where only the perpetrator and the rape victim are present)[7] allows this evidentiary approach and the conclusion the lower courts reached.
	GR No. 183577 2010-02-01	PEOPLE v. HILARIO ESCOTON DEL CASTILLO, J.
Much less convincing is the proposition of the appellant that "AAA" filed the complaint against him because she and her other relatives were harboring ill feelings and evil motives against him. Ill motives become inconsequential where there are affirmative or categorical declarations establishing the accountability of the appellant for the felony, as in this case.[24] Moreover, we have observed that persons convicted of rape sometimes attribute the charges against them to family feuds, resentment or revenge.[25] However, as borne out by numerous cases, family resentment, revenge or feuds have never swayed us from giving full credence to the testimony of a complainant for rape, especially a minor who remained steadfast and unyielding throughout the trial that she was sexually violated.[26]
	GR No. 183619 2009-10-13	PEOPLE v. SALVINO SUMINGWA NACHURA, J.
While appellant's conviction was primarily based on the prosecution's testimonial evidence, the same was corroborated by physical evidence consisting of the medical findings of the medico-legal officer that there were hymenal lacerations. When a rape victim's account is straightforward and candid, and is corroborated by the medical findings of the examining physician, the same is sufficient to support a conviction for rape.[41]
	GR No. 185203 2009-09-17	PEOPLE v. DOMINGO ARAOJO VELASCO JR., J.
As the Court has often repeated, the issue of credibility is a matter best addressed by the trial court which had the chance to observe the demeanor of the witnesses while testifying. For this reason, the Court, as earlier stressed, accords great weight and even finality to factual findings of the trial court, especially its assessments of the witnesses and their credibility, barring arbitrariness or oversight of some fact or circumstance of weight and substance.[15] Testimonies of child-victims are normally given full weight and credit, since when a girl, particularly if she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape has in fact been committed. When the offended party is of tender age and immature, courts are inclined to give credit to her account of what transpired, considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified is not true.[16] Youth and immaturity are generally badges of truth and sincerity.[17]
	GR No. 173473 2008-12-17	PEOPLE v. BETH TEMPORADA YNARES-SANTIAGO, J.
In the instant case, we find no reason to depart from the rule that findings of fact of the trial court on the credibility of witnesses and their testimonies are generally accorded great respect by an appellate court. The assessment of credibility of witnesses is a matter best left to the trial court because it is in the position to observe that elusive and incommunicable evidence of the witnesses' deportment on the stand while testifying, which opportunity is denied to the appellate courts.[13] Further, there is no showing of any ill-motive on the part of the prosecution witnesses in testifying against appellant. Absent such improper motive, the presumption is that they were not so actuated and their testimony is entitled to full weight and credit.
	GR No. 177749 2007-12-17	PEOPLE v. MANUEL AGUILAR CHICO-NAZARIO, J.
It is well-settled that the appellant may be convicted of rape based solely on the testimony of the victim, as long as the same is competent and credible. This is primarily because the crime of rape is usually committed in a private place where only the aggressor and the rape victim are present.[33] Moreover, even the trial court mentioned in its Decision that even in the absence of the corroborative testimonies of the prosecution's other witnesses, the testimony of AAA can stand on its ground and is enough to convict the appellant.[34]
	GR NO. 172118 2007-04-24	PEOPLE v. WARLITO C. FERNANDEZ CALLEJO, SR., J.
It is also settled that the accused may be convicted solely on the basis of the victim's testimony, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.[49] If the victim's testimony meets the test of credibility, this is sufficient to convict the accused. The credibility of the victim is almost always the single most important issue to hurdle.[50]
	GR NO. 166401 2006-10-30	PEOPLE v. ALFREDO BON TINGA, J.
Besides, no sane woman, least of all a child, would concoct a story of defloration, allow an examination of her private parts and subject herself to public trial or ridicule if she has not in truth, been a victim of rape and impelled to seek justice for the wrong done to her. Testimonies of child-victims are normally given full weight and credit, since 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 show that rape has been committed. Youth and immaturity are generally badges of truth and sincerity.[44] The weight of such testimonies may be countered by physical evidence to the contrary, or indubitable proof that the accused could not have committed the rape, but in the absence of such countervailing proof, these testimonies shall be accorded utmost value.
	GR NO. 172322 2006-09-08	PEOPLE v. RENE SANTOS TINGA, J.
The argument is tenuous. As has been pointed out in People v. Guambor:[35]
	GR NO. 172322 2006-09-08	PEOPLE v. RENE SANTOS TINGA, J.
Much less convincing is appellant's proposition that ill feelings and ill motives of the victim's mother impelled the filing of the charges against him. Ill-motives become inconsequential where there are affirmative or categorical declarations establishing appellant's accountability for the felony.[52] We have, furthermore, observed not a few persons convicted of rape have attributed the charges against them to family feuds, resentment or revenge.[53] However, as borne out by a plethora of cases, family resentment, revenge or feuds have never swayed us from giving full credence to the testimony of a complainant for rape, especially a minor who remained steadfast and unyielding throughout the direct and cross- examination that she was sexually abused.[54] It would take a certain degree of perversity on the part of a parent, especially a mother, to concoct a false charge of rape and then use her daughter as an instrument to settle her grudge.[55]
	GR NO. 168101 2006-02-13	PEOPLE v. GREGORIO CORPUZ Y ESPIRITU PER CURIAM
In rape cases, the accused may be convicted solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing and consistent with human nature and the normal course of things.[13]
	GR No. 157269 2004-06-03	PEOPLE v. JAIME “JIMBOY” ANTONIO Y MACARIO YNARES-SATIAGO, J.
The award of moral damages is correct. It is automatically granted in rape cases without need of further proof other than the commission of the crime, because it is assumed that a rape victim has actually suffered moral injuries entitling her to such award. However, it must be reduced from P100,000.00 to P50,000.00 based on prevailing jurisprudence.[19] Moral damages are separate and distinct from civil indemnity.[20]

PEOPLE v. NELSON GUAMBOR