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GR No. 217975

2015-11-23

MENDOZA, J.

In addition, AAA's testimony was corroborated by the medical findings of Dr. Collado that the healed hymenal lacerations at 9:00 o'clock notch on her private part could have been caused by the penetration of a man's penis. Dr. Collado also disclosed that her hymen was no longer intact. It has been said that when the testimony of a rape victim is consistent with the medical findings, a sufficient basis exists to warrant a conclusion that the essential requisite of carnal knowledge has thereby been established.[15] Hence, the testimony of Dr. Collado strengthens even more AAA's claim of rape.

GR No. 173307

2013-07-17

PEOPLE v. VICTORINO REYES

BERSAMIN, J.

Finally, although the RTC and the CA correctly imposed reclusion perpetua because the crime was simple rape, we need to revise the civil liability fixed and allowed by the RTC in order to have it accord with pertinent jurisprudence to the effect that civil indemnity of P50,000.00 and moral damages of P50,000.00 should be awarded to the victim of simple rape without need of proof other than the fact of rape.[28] This is because the victim unquestionably suffered actual loss and moral injuries from her experience. In addition, the attendance of AAA's minority as an aggravating circumstance, which, although not a proper basis to raise the penal sanction on account of the failure to allege it in the information, should still justify the grant of exemplary damages in order to set a public example and to establish a deterrent against elders who abuse and corrupt the youth.[29] According to People v. Catubig,[30] exemplary damages are justified regardless of whether or not the generic or qualifying aggravating circumstances are alleged in the information, considering that the grant of such damages pursuant to Article 2230 of the Civil Code is intended for the sole benefit of the victim and does not affect the criminal liability, the exclusive concern of the State. The grant in this regard should be in the sum of P30,000.00.[31]

GR No. 175876

2013-02-20

PEOPLE v. TOMAS TEODORO Y ANGELES

BERSAMIN, J.

Both lower courts thereby erred. There is no longer any debate that the victim in statutory rape is entitled to a civil indemnity of P50,000.00, moral damages of P50,000.00, and exemplary damages of P30,000.00. The award of civil indemnity of P50,000.00 is mandatory upon the finding of the fact of rape.[36] Similarly, the award of moral damages of P50,000.00 is mandatory, and made without need of allegation and proof other than that of the fact of rape,[37] for it is logically assumed that the victim suffered moral injuries from her ordeal. In addition, exemplary damages of P30,000.00 are justified under Article 2229 of the Civil Code [38] to set an example for the public good and to serve as deterrent to those who abuse the young.[39]

GR No. 183097

2012-09-12

PEOPLE v. ANTONINO VENTURINA

DEL CASTILLO, J.

Moreover, "AAA's" testimony is corroborated by the findings of Dr. Viray. The doctor found deep healed lacerations in "AAA's" hymen. It is settled that "when the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that the essential requisite of carnal knowledge has thereby been established."[12]

GR No. 183569

2011-04-13

PEOPLE v. VICENTE PUBLICO Y AMODIA

SERENO, J.

As a general rule, appellate courts will not disturb the findings of the trial court on the credibility of witnesses. As we have held many times, "evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court, because of its unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination." [14] Unless trial courts are found to have plainly overlooked certain facts of substance and value, their conclusions on the credibility of witnesses should be respected. [15]

GR No. 175831

2011-04-12

PEOPLE v. FLORANTE RELANES

DEL CASTILLO, J.

Regarding damages, we sustain the appellate court's award of civil indemnity to "AAA" in the amount of P75,000.00 for each case. "[I]f the crime of rape is qualified by circumstances which warrant the imposition of the death penalty by applicable amendatory laws, the complainant should be awarded P75,000.00 for each count of rape as civil indemnity."[37] We also affirm the award of moral and exemplary damages. In rape cases, "[m]oral 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 for the experience she underwent."[38] Exemplary damages, on the other hand, are given by way of public example and to protect the young from sexual abuse. However, the moral and exemplary damages in the amount of P50,000.00 and P25,000.00, respectively, should be increased to P75,000.00 and P30,000.00 consistent with relevant jurisprudence.[39] In addition, interest at the rate of six percent (6%) per annum shall be imposed on all damages awarded from the date of finality of this judgment, likewise pursuant to prevailing jurisprudence.[40]

GR No. 191754

2011-04-11

PEOPLE v. GREGORIO FELIPE Y CALINGANGAN

PERALTA, J.

Generally, the Court will not disturb the findings of the trial court on the credibility of witnesses, as it was in the better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court; it had the unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is entitled to respect unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[11]

GR No. 188855

2010-12-08

PEOPLE v. RUEL TAMANO Y PASIA

PEREZ, J.

This Court noted that the aforesaid testimony of AAA was given without flourish and innuendo.[51] As aptly observed by the trial court: x x x despite [AAA's] mental condition and limited communication skills, she was able to perceive what happened to her and effectively conveyed it in her own unique way. Her description on how she was molested, her telegraphic answer to questions as to how the raped occurred due to her limited vocabulary vividly portrayed that the words came from an innocent girl and point to an undeniable fact that she was not coached.[52] [Emphases supplied].

GR No. 168103

2010-08-03

PEOPLE v. ALEJANDRO RELLOTA Y TADEO

PERALTA, J.

Hence, the trial court did not err in appreciating the testimony of AAA. The unbroken line of jurisprudence is that this Court will not disturb the findings of the trial court as to the credibility of witnesses, considering that it is in a better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court, because of its unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is respected unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[35] Furthermore, the above testimonies of AAA positively identifying appellant as the one who defiled her were all the more strengthened by the Medico-Legal Report[36] conducted by Dr. Rosaline Onggao, who also testified that: PUBLIC PROSECUTOR: Can you tell us what is in the findings which would verify or confirm the information given to you by AAA that she was sexually abused for several times?

GR No. 178274

2010-03-05

PEOPLE v. AURELIO MATUNHAY

BRION, J.

Subject to the observed paucity of evidence discussed below on the four other counts of rape, the Court will not disturb the findings of the trial court on the credibility of witnesses, as it was in the better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court; it had the unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is entitled to respect unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[23]

GR No. 161902

2009-09-11

EDGAR MERCADO v. PEOPLE

PERALTA, J.

In the face of the credible and reliable positive identification made by Gonzales, petitioner's defense of alibi is absolutely unavailing. As held in People v. Tormis,[21] "the defense of alibi, being inherently weak, cannot prevail over the clear and positive identification of the accused as the perpetrator of the crime." Indeed, petitioner's bare allegation that he arrived in Bacolod only on the morning of December 24, 1996 cannot be given much credence since it is unsupported by evidence of the time of his travel or the time he left Iloilo, such as a ticket from the ferry he boarded. There is no evidence presented showing that petitioner was actually in Iloilo as of the time of the commission of the crime. The witnesses petitioner presented only proved that they saw him only on the morning of December 24, 1996, but this does not prove that petitioner could not have been in Bacolod at an earlier time before they saw him.

	GR No. 217975 2015-11-23	PEOPLE v. BERNARDINO BIALA MENDOZA, J.
In addition, AAA's testimony was corroborated by the medical findings of Dr. Collado that the healed hymenal lacerations at 9:00 o'clock notch on her private part could have been caused by the penetration of a man's penis. Dr. Collado also disclosed that her hymen was no longer intact. It has been said that when the testimony of a rape victim is consistent with the medical findings, a sufficient basis exists to warrant a conclusion that the essential requisite of carnal knowledge has thereby been established.[15] Hence, the testimony of Dr. Collado strengthens even more AAA's claim of rape.
	GR No. 173307 2013-07-17	PEOPLE v. VICTORINO REYES BERSAMIN, J.
Finally, although the RTC and the CA correctly imposed reclusion perpetua because the crime was simple rape, we need to revise the civil liability fixed and allowed by the RTC in order to have it accord with pertinent jurisprudence to the effect that civil indemnity of P50,000.00 and moral damages of P50,000.00 should be awarded to the victim of simple rape without need of proof other than the fact of rape.[28] This is because the victim unquestionably suffered actual loss and moral injuries from her experience. In addition, the attendance of AAA's minority as an aggravating circumstance, which, although not a proper basis to raise the penal sanction on account of the failure to allege it in the information, should still justify the grant of exemplary damages in order to set a public example and to establish a deterrent against elders who abuse and corrupt the youth.[29] According to People v. Catubig,[30] exemplary damages are justified regardless of whether or not the generic or qualifying aggravating circumstances are alleged in the information, considering that the grant of such damages pursuant to Article 2230 of the Civil Code is intended for the sole benefit of the victim and does not affect the criminal liability, the exclusive concern of the State. The grant in this regard should be in the sum of P30,000.00.[31]
	GR No. 175876 2013-02-20	PEOPLE v. TOMAS TEODORO Y ANGELES BERSAMIN, J.
Both lower courts thereby erred. There is no longer any debate that the victim in statutory rape is entitled to a civil indemnity of P50,000.00, moral damages of P50,000.00, and exemplary damages of P30,000.00. The award of civil indemnity of P50,000.00 is mandatory upon the finding of the fact of rape.[36] Similarly, the award of moral damages of P50,000.00 is mandatory, and made without need of allegation and proof other than that of the fact of rape,[37] for it is logically assumed that the victim suffered moral injuries from her ordeal. In addition, exemplary damages of P30,000.00 are justified under Article 2229 of the Civil Code [38] to set an example for the public good and to serve as deterrent to those who abuse the young.[39]
	GR No. 183097 2012-09-12	PEOPLE v. ANTONINO VENTURINA DEL CASTILLO, J.
Moreover, "AAA's" testimony is corroborated by the findings of Dr. Viray. The doctor found deep healed lacerations in "AAA's" hymen. It is settled that "when the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that the essential requisite of carnal knowledge has thereby been established."[12]
	GR No. 183569 2011-04-13	PEOPLE v. VICENTE PUBLICO Y AMODIA SERENO, J.
As a general rule, appellate courts will not disturb the findings of the trial court on the credibility of witnesses. As we have held many times, "evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court, because of its unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination." [14] Unless trial courts are found to have plainly overlooked certain facts of substance and value, their conclusions on the credibility of witnesses should be respected. [15]
	GR No. 175831 2011-04-12	PEOPLE v. FLORANTE RELANES DEL CASTILLO, J.
Regarding damages, we sustain the appellate court's award of civil indemnity to "AAA" in the amount of P75,000.00 for each case. "[I]f the crime of rape is qualified by circumstances which warrant the imposition of the death penalty by applicable amendatory laws, the complainant should be awarded P75,000.00 for each count of rape as civil indemnity."[37] We also affirm the award of moral and exemplary damages. In rape cases, "[m]oral 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 for the experience she underwent."[38] Exemplary damages, on the other hand, are given by way of public example and to protect the young from sexual abuse. However, the moral and exemplary damages in the amount of P50,000.00 and P25,000.00, respectively, should be increased to P75,000.00 and P30,000.00 consistent with relevant jurisprudence.[39] In addition, interest at the rate of six percent (6%) per annum shall be imposed on all damages awarded from the date of finality of this judgment, likewise pursuant to prevailing jurisprudence.[40]
	GR No. 191754 2011-04-11	PEOPLE v. GREGORIO FELIPE Y CALINGANGAN PERALTA, J.
Generally, the Court will not disturb the findings of the trial court on the credibility of witnesses, as it was in the better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court; it had the unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is entitled to respect unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[11]
	GR No. 188855 2010-12-08	PEOPLE v. RUEL TAMANO Y PASIA PEREZ, J.
This Court noted that the aforesaid testimony of AAA was given without flourish and innuendo.[51] As aptly observed by the trial court: x x x despite [AAA's] mental condition and limited communication skills, she was able to perceive what happened to her and effectively conveyed it in her own unique way. Her description on how she was molested, her telegraphic answer to questions as to how the raped occurred due to her limited vocabulary vividly portrayed that the words came from an innocent girl and point to an undeniable fact that she was not coached.[52] [Emphases supplied].
	GR No. 168103 2010-08-03	PEOPLE v. ALEJANDRO RELLOTA Y TADEO PERALTA, J.
Hence, the trial court did not err in appreciating the testimony of AAA. The unbroken line of jurisprudence is that this Court will not disturb the findings of the trial court as to the credibility of witnesses, considering that it is in a better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court, because of its unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is respected unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[35] Furthermore, the above testimonies of AAA positively identifying appellant as the one who defiled her were all the more strengthened by the Medico-Legal Report[36] conducted by Dr. Rosaline Onggao, who also testified that: PUBLIC PROSECUTOR: Can you tell us what is in the findings which would verify or confirm the information given to you by AAA that she was sexually abused for several times?
	GR No. 178274 2010-03-05	PEOPLE v. AURELIO MATUNHAY BRION, J.
Subject to the observed paucity of evidence discussed below on the four other counts of rape, the Court will not disturb the findings of the trial court on the credibility of witnesses, as it was in the better position to observe their candor and behavior on the witness stand. Evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court; it had the unique opportunity to observe the witnesses and their demeanor, conduct, and attitude, especially under cross-examination. Its assessment is entitled to respect unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case.[23]
	GR No. 161902 2009-09-11	EDGAR MERCADO v. PEOPLE PERALTA, J.
In the face of the credible and reliable positive identification made by Gonzales, petitioner's defense of alibi is absolutely unavailing. As held in People v. Tormis,[21] "the defense of alibi, being inherently weak, cannot prevail over the clear and positive identification of the accused as the perpetrator of the crime." Indeed, petitioner's bare allegation that he arrived in Bacolod only on the morning of December 24, 1996 cannot be given much credence since it is unsupported by evidence of the time of his travel or the time he left Iloilo, such as a ticket from the ferry he boarded. There is no evidence presented showing that petitioner was actually in Iloilo as of the time of the commission of the crime. The witnesses petitioner presented only proved that they saw him only on the morning of December 24, 1996, but this does not prove that petitioner could not have been in Bacolod at an earlier time before they saw him.

PEOPLE v. REGINO TORMIS