Lawyerly

GR No. 175685

2013-08-07

BRION, J.

Meanwhile, Lot No. 2624 was divided into two smaller lots, described as Lot Nos. 2624-A and 2624-B with areas of 2,130 square meters and 500 square meters, respectively.[9] Respondent Jesus Cabanto bought the smaller lot (Lot No. 2624-B) from Angeles.[10] This led to the cancellation of OCT No. 1546, and the issuance of Transfer Certificate of Title (TCT) No. 770 for Lot No. 2624-A, in the name of Angeles, and TCT No. 771 for Lot No. 2624-B, in the name of Cabanto.[11]

GR No. 183577

2010-02-01

PEOPLE v. HILARIO ESCOTON

DEL CASTILLO, J.

The testimony of rape victims are given full weight and credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subjected to a public trial, if she was not motivated solely by the desire to seek justice for the wrong done to her.[17] It is highly improbable that a girl of tender years who is not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is false.[18] Considering that the victim in this case underwent a harrowing experience and exposed herself to the rigors of public trial, it is unlikely that she would concoct false accusations against the appellant, who is her uncle.

GR No. 182791

2009-02-10

PEOPLE v. ELISTER BASMAYOR Y GRASCILLA

CHICO-NAZARIO, J.

This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being the subject of a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[33] Youth and immaturity are generally badges of truth.[34] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[35]

GR No. 173477

2009-02-04

PEOPLE v. FRANCO DE GUZMAN

QUISUMBING, J.

As to the second issue, the trial court and Court of Appeals correctly dismissed the appellant's defense of alibi. Alibi is the weakest of all defenses, because it is easy to concoct and difficult to disprove. For it to prosper, proof that the defendant was somewhere else when the crime was committed is insufficient. He must likewise demonstrate that it was physically impossible for him to have been at the scene of the crime at the time. In the case before us, the appellant himself testified that he was at the very same area where the crime was committed. He never testified that it was physically impossible for him to be at the scene of the crime on the date and at the time it happened. What is clear is that he was within the vicinity of the locus criminis.[25]

GR No. 182924

2008-12-24

PEOPLE v. JOSE PEREZ

CHICO-NAZARIO, J.

This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[36] Youth and immaturity are generally badges of truth.[37] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[38]

GR No. 173052

2008-12-16

PEOPLE v. ROGELIO PELAGIO Y BERMUDO

AUSTRIA-MARTINEZ, J.

To determine the innocence or guilt of an accused in a rape case, the courts are guided by three well-entrenched principles: (1) an accusation of rape can be made with facility and while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant should be scrutinized with great 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.[13] As a result of these guiding principles, credibility becomes the single most important issue.[14]

GR No. 177822

2008-06-17

PEOPLE v. HILARIO OPONG Y TAÑESA

CHICO-NAZARIO, J.

As a result of these guiding principles, the credibility of the complainant becomes the single most important issue.[29] If the testimony of the victim is credible, convincing and consistent with human nature, and the normal course of things, the accused may be convicted solely on the basis thereof.[30]

GR No. 177749

2007-12-17

PEOPLE v. MANUEL AGUILAR

CHICO-NAZARIO, J.

This Court, upon examining the records of the present case, fully agrees in the findings of both the trial court and the appellate court that the testimony of AAA is credible and enough to convict the appellant even without the corroborating testimonies of the other prosecution witnesses. Her testimony on how she was raped by the appellant on 24 June 1997 was characterized by the trial court and affirmed by the Court of Appeals as clear, straightforward and bereft of any material or significant inconsistencies. Further, we note that while testifying, AAA broke down in tears.[40] The crying of a victim during her testimony is eloquent evidence of the credibility of the rape charge with the verity borne out of human nature and experience.[41] Similarly, no 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.[42] It is also highly inconceivable for a girl to provide details of a rape and ascribe such wickedness to her "stepfather" just because she resents being disciplined by him since, by thus charging him, she would also expose herself to extreme humiliation, even stigma.[43] 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 was committed.[44] Youth and immaturity could indeed be badges of truth. This observation is a matter of judicial cognizance borne out by human nature and experience. There could not have been a more powerful testament to the truth than this "public baring of unspoken grief."[45] More so, it is an accepted doctrine that in the absence of evidence of improper motive on the part of the victim to falsely testify against the accused, her testimony deserves credence.[46] And in this case, it was never shown that the complainant had an ill motive in filing a case against the appellant other than seeking justice for what had happened to her.

GR NO. 176069

2007-10-05

PEOPLE v. MARIO CONSTANTINO

CARPIO, J.

We also reject appellant's contention that AAA's grandmother coached AAA to identify appellant as the rapist. It should be borne in mind that AAA is a 15-year old lass whose mental age is that of a 7-year old child. It would have been difficult for AAA to concoct a grave charge of rape against appellant, more so narrate the details of how appellant ravished her, if such were not the truth. Also, it is highly unnatural for a grandmother to expose her granddaughter to the shame and scandal attached to a rape trial.[11]

GR NO. 169962

2007-07-12

PEOPLE v. RAUL CENAHONON

NACHURA, J.

In fine, there is no showing that the lower court has overlooked, misunderstood, or misapplied any fact or circumstance of weight and substance that would warrant the reversal of the conviction. Further, the assessment of the credibility of witnesses by the trial court is binding and conclusive on appeal because the trial court had the opportunity to evaluate conflicting testimonies and observe the demeanor of witnesses while on the stand.[49]

GR NO. 170471

2007-05-11

PEOPLE v. FRANCISCO BUBAN

QUISUMBING, J.

As for Bubanï¿½s alibi, alibi is the weakest of all defenses. It is easy to concoct, although difficult to disprove. For alibi to prosper, proof that the defendant was somewhere else when the crime was committed is insufficient. He must demonstrate that it was physically impossible for him to have been at the scene of the crime at the time. In this case, appellant himself testified that he was at the very same area where the house of the victim was located. He never testified that it was physically impossible for him to be at the scene of the crime on the date and at the time it happened. The trial court found that he was within the vicinity of the locus criminis.[45] We are not persuaded to discard this factual finding without the appellant's ironclad proof of his alibi.

GR NO. 171020

2007-03-14

PEOPLE v. ALFREDO PANGILINAN Y TRINIDAD

CHICO-NAZARIO, J.

This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[28] Youth and immaturity are generally badges of truth.[29] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[30] A rape victim's testimony against her parent is entitled to great weight since Filipino children have a natural reverence and respect for their elders. These values are so deeply ingrained in Filipino families and it is unthinkable for a daughter to brazenly concoct a story of rape against her, if such were not true.[31] Her credibility was bolstered beyond reproach by her spontaneous emotional breakdown during trial.[32]

GR NO. 168649

2006-12-06

PEOPLE v. JOSE ALVIZO AUDINE

CHICO-NAZARIO, J.

We find this hard to believe. Motives such as feuds, resentment and revenge have never swayed us from giving full credence to the testimony of a minor complainant.[36] This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[37] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[38] Youth and immaturity are generally badges of truth.[39] Full weight and credit should, indeed, be accorded AAA's testimony. It is very unlikely for her to accuse her father of so heinous a crime if it were not true. Her credibility was bolstered beyond reproach by her spontaneous emotional breakdown during trial.[40]

GR NO. 166546

2006-09-26

PEOPLE v. ROGELIO ARSAYO Y LAVAQUIZ

CHICO-NAZARIO, J.

This claim was never substantiated. Even assuming arguendo that the victim resented appellant for having allegedly scolded her, such a reason is too flimsy to be believed by this Court. This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[32] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[33] Youth and immaturity are generally badges of truth.[34] Indeed, AAA's testimony deserves full weight and credit. Having just entered her teen years, it is very unlikely for her to accuse her stepfather - the person who treated her as his own child, gave her his name, and sent her to school - of so heinous a crime if it were not true.

GR NO. 168442

2006-08-30

PEOPLE v. OSCAR ARANGO Y ALEGRE

CHICO-NAZARIO, J.

This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[28] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[29] In this case, considering that the victim was of tender age, have undergone a harrowing experience, and have exposed herself to the rigors of public trial, we find it improbable that she would impute so grave a crime to accused-appellant, a man she considered her "ninong."

GR NO. 126780

2005-02-17

YHT REALTY CORPORATION v. CA

TINGA, J.

The trial court had the occasion to observe the demeanor of McLoughlin while testifying which reflected the veracity of the facts testified to by him. On this score, we give full credence to the appreciation of testimonial evidence by the trial court especially if what is at issue is the credibility of the witness. The oft-repeated principle is that where the credibility of a witness is an issue, the established rule is that great respect is accorded to the evaluation of the credibility of witnesses by the trial court.[31] The trial court is in the best position to assess the credibility of witnesses and their testimonies because of its unique opportunity to observe the witnesses firsthand and note their demeanor, conduct and attitude under grilling examination.[32]

	GR No. 175685 2013-08-07	REPUBLIC v. ANGELES BELLATE BRION, J.
Meanwhile, Lot No. 2624 was divided into two smaller lots, described as Lot Nos. 2624-A and 2624-B with areas of 2,130 square meters and 500 square meters, respectively.[9] Respondent Jesus Cabanto bought the smaller lot (Lot No. 2624-B) from Angeles.[10] This led to the cancellation of OCT No. 1546, and the issuance of Transfer Certificate of Title (TCT) No. 770 for Lot No. 2624-A, in the name of Angeles, and TCT No. 771 for Lot No. 2624-B, in the name of Cabanto.[11]
	GR No. 183577 2010-02-01	PEOPLE v. HILARIO ESCOTON DEL CASTILLO, J.
The testimony of rape victims are given full weight and credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subjected to a public trial, if she was not motivated solely by the desire to seek justice for the wrong done to her.[17] It is highly improbable that a girl of tender years who is not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is false.[18] Considering that the victim in this case underwent a harrowing experience and exposed herself to the rigors of public trial, it is unlikely that she would concoct false accusations against the appellant, who is her uncle.
	GR No. 182791 2009-02-10	PEOPLE v. ELISTER BASMAYOR Y GRASCILLA CHICO-NAZARIO, J.
This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being the subject of a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[33] Youth and immaturity are generally badges of truth.[34] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[35]
	GR No. 173477 2009-02-04	PEOPLE v. FRANCO DE GUZMAN QUISUMBING, J.
As to the second issue, the trial court and Court of Appeals correctly dismissed the appellant's defense of alibi. Alibi is the weakest of all defenses, because it is easy to concoct and difficult to disprove. For it to prosper, proof that the defendant was somewhere else when the crime was committed is insufficient. He must likewise demonstrate that it was physically impossible for him to have been at the scene of the crime at the time. In the case before us, the appellant himself testified that he was at the very same area where the crime was committed. He never testified that it was physically impossible for him to be at the scene of the crime on the date and at the time it happened. What is clear is that he was within the vicinity of the locus criminis.[25]
	GR No. 182924 2008-12-24	PEOPLE v. JOSE PEREZ CHICO-NAZARIO, J.
This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[36] Youth and immaturity are generally badges of truth.[37] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[38]
	GR No. 173052 2008-12-16	PEOPLE v. ROGELIO PELAGIO Y BERMUDO AUSTRIA-MARTINEZ, J.
To determine the innocence or guilt of an accused in a rape case, the courts are guided by three well-entrenched principles: (1) an accusation of rape can be made with facility and while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant should be scrutinized with great 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.[13] As a result of these guiding principles, credibility becomes the single most important issue.[14]
	GR No. 177822 2008-06-17	PEOPLE v. HILARIO OPONG Y TAÑESA CHICO-NAZARIO, J.
As a result of these guiding principles, the credibility of the complainant becomes the single most important issue.[29] If the testimony of the victim is credible, convincing and consistent with human nature, and the normal course of things, the accused may be convicted solely on the basis thereof.[30]
	GR No. 177749 2007-12-17	PEOPLE v. MANUEL AGUILAR CHICO-NAZARIO, J.
This Court, upon examining the records of the present case, fully agrees in the findings of both the trial court and the appellate court that the testimony of AAA is credible and enough to convict the appellant even without the corroborating testimonies of the other prosecution witnesses. Her testimony on how she was raped by the appellant on 24 June 1997 was characterized by the trial court and affirmed by the Court of Appeals as clear, straightforward and bereft of any material or significant inconsistencies. Further, we note that while testifying, AAA broke down in tears.[40] The crying of a victim during her testimony is eloquent evidence of the credibility of the rape charge with the verity borne out of human nature and experience.[41] Similarly, no 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.[42] It is also highly inconceivable for a girl to provide details of a rape and ascribe such wickedness to her "stepfather" just because she resents being disciplined by him since, by thus charging him, she would also expose herself to extreme humiliation, even stigma.[43] 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 was committed.[44] Youth and immaturity could indeed be badges of truth. This observation is a matter of judicial cognizance borne out by human nature and experience. There could not have been a more powerful testament to the truth than this "public baring of unspoken grief."[45] More so, it is an accepted doctrine that in the absence of evidence of improper motive on the part of the victim to falsely testify against the accused, her testimony deserves credence.[46] And in this case, it was never shown that the complainant had an ill motive in filing a case against the appellant other than seeking justice for what had happened to her.
	GR NO. 176069 2007-10-05	PEOPLE v. MARIO CONSTANTINO CARPIO, J.
We also reject appellant's contention that AAA's grandmother coached AAA to identify appellant as the rapist. It should be borne in mind that AAA is a 15-year old lass whose mental age is that of a 7-year old child. It would have been difficult for AAA to concoct a grave charge of rape against appellant, more so narrate the details of how appellant ravished her, if such were not the truth. Also, it is highly unnatural for a grandmother to expose her granddaughter to the shame and scandal attached to a rape trial.[11]
	GR NO. 169962 2007-07-12	PEOPLE v. RAUL CENAHONON NACHURA, J.
In fine, there is no showing that the lower court has overlooked, misunderstood, or misapplied any fact or circumstance of weight and substance that would warrant the reversal of the conviction. Further, the assessment of the credibility of witnesses by the trial court is binding and conclusive on appeal because the trial court had the opportunity to evaluate conflicting testimonies and observe the demeanor of witnesses while on the stand.[49]
	GR NO. 170471 2007-05-11	PEOPLE v. FRANCISCO BUBAN QUISUMBING, J.
As for Bubanï¿½s alibi, alibi is the weakest of all defenses. It is easy to concoct, although difficult to disprove. For alibi to prosper, proof that the defendant was somewhere else when the crime was committed is insufficient. He must demonstrate that it was physically impossible for him to have been at the scene of the crime at the time. In this case, appellant himself testified that he was at the very same area where the house of the victim was located. He never testified that it was physically impossible for him to be at the scene of the crime on the date and at the time it happened. The trial court found that he was within the vicinity of the locus criminis.[45] We are not persuaded to discard this factual finding without the appellant's ironclad proof of his alibi.
	GR NO. 171020 2007-03-14	PEOPLE v. ALFREDO PANGILINAN Y TRINIDAD CHICO-NAZARIO, J.
This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[28] Youth and immaturity are generally badges of truth.[29] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[30] A rape victim's testimony against her parent is entitled to great weight since Filipino children have a natural reverence and respect for their elders. These values are so deeply ingrained in Filipino families and it is unthinkable for a daughter to brazenly concoct a story of rape against her, if such were not true.[31] Her credibility was bolstered beyond reproach by her spontaneous emotional breakdown during trial.[32]
	GR NO. 168649 2006-12-06	PEOPLE v. JOSE ALVIZO AUDINE CHICO-NAZARIO, J.
We find this hard to believe. Motives such as feuds, resentment and revenge have never swayed us from giving full credence to the testimony of a minor complainant.[36] This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[37] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[38] Youth and immaturity are generally badges of truth.[39] Full weight and credit should, indeed, be accorded AAA's testimony. It is very unlikely for her to accuse her father of so heinous a crime if it were not true. Her credibility was bolstered beyond reproach by her spontaneous emotional breakdown during trial.[40]
	GR NO. 166546 2006-09-26	PEOPLE v. ROGELIO ARSAYO Y LAVAQUIZ CHICO-NAZARIO, J.
This claim was never substantiated. Even assuming arguendo that the victim resented appellant for having allegedly scolded her, such a reason is too flimsy to be believed by this Court. This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[32] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[33] Youth and immaturity are generally badges of truth.[34] Indeed, AAA's testimony deserves full weight and credit. Having just entered her teen years, it is very unlikely for her to accuse her stepfather - the person who treated her as his own child, gave her his name, and sent her to school - of so heinous a crime if it were not true.
	GR NO. 168442 2006-08-30	PEOPLE v. OSCAR ARANGO Y ALEGRE CHICO-NAZARIO, J.
This Court has held time and again that testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her.[28] It is highly improbable that a girl of tender years, one not yet exposed to the ways of the world, would impute to any man a crime so serious as rape if what she claims is not true.[29] In this case, considering that the victim was of tender age, have undergone a harrowing experience, and have exposed herself to the rigors of public trial, we find it improbable that she would impute so grave a crime to accused-appellant, a man she considered her "ninong."
	GR NO. 126780 2005-02-17	YHT REALTY CORPORATION v. CA TINGA, J.
The trial court had the occasion to observe the demeanor of McLoughlin while testifying which reflected the veracity of the facts testified to by him. On this score, we give full credence to the appreciation of testimonial evidence by the trial court especially if what is at issue is the credibility of the witness. The oft-repeated principle is that where the credibility of a witness is an issue, the established rule is that great respect is accorded to the evaluation of the credibility of witnesses by the trial court.[31] The trial court is in the best position to assess the credibility of witnesses and their testimonies because of its unique opportunity to observe the witnesses firsthand and note their demeanor, conduct and attitude under grilling examination.[32]

PEOPLE v. GUILLERMO ANDALES