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GR No. 193169

2015-04-06

DEL CASTILLO, J.

Besides, findings of facts of the RTC, its calibration of the testimonial evidence, its assessment of the probative weight thereof, as well as its conclusions anchored on the said findings, are accorded high respect if not conclusive effect when affirmed by the CA,[14] as in this case. After all, the RTC "had the opportunity to observe the witnesses on the stand and detect if they were telling the truth."[15] "To [thus] accord with the established doctrine of finality and bindingness of the trial court's findings of fact, [the Court shall] not disturb [the] findings of fact of the RTC, particularly after their affirmance by the CA"[16] as petitioner was not able to sufficiently establish any extraordinary circumstance which merits a departure from the said doctrine.[17]

GR No. 179935

2010-04-19

PEOPLE v. ROGELIO ASIS Y LACSON

DEL CASTILLO, J.

We are likewise not swayed by appellant's assertion that "AAA" filed the rape charges against him because he disallowed her to work in Manila. This claim is not only unsubstantiated, but likewise unworthy of belief. As aptly held by the trial court, it strains credulity that the victim would concoct a tale of rape against her own father, allow an examination of her private parts and subject herself to a public trial simply because she was not allowed to work in Manila. We have consistently held 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 show that rape was committed.[30]

GR No. 181255

2009-10-16

PEOPLE v. ERNESTO PILI

CHICO-NAZARIO, J.

crime of rape where only two persons are usually involved, the testimony of the private complainant must 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 for the defense.[23] It is well-established that when a woman says that she has been raped, she says, in effect, all that is necessary to show that she has indeed been raped.[24] A victim of rape would not come out in the open if her motive were anything other than to obtain

GR No. 179714

2009-10-02

PEOPLE v. RODOLFO LOPEZ

PERALTA, J.

This Court has repeatedly held that the evaluation of the testimony of the witnesses by the trial court is accorded the highest respect on appeal, because the court below had the opportunity to observe the witnesses on the stand and detect if they were telling the truth. This assessment is binding upon the appellate court in the absence of a clear showing that it was reached arbitrarily, or that the trial court plainly overlooked certain facts of substance or value that, if considered, might affect the result of the case.[21]

GR No. 179714

2009-10-02

PEOPLE v. RODOLFO LOPEZ

PERALTA, J.

For his defense, appellant Lopez merely denied committing the crime and even pointed an accusatory finger to the six-year-old brother of the victim, whom the former allegedly saw fingering the same victim. However, it is a time-honored principle that the positive and categorical assertions of a witness generally prevail over bare denials. Affirmative testimony from a credible witness is stronger and more trustworthy than a bare self-serving testimony.[29]

GR No. 184791

2009-04-16

PEOPLE v. PEDRO NOGPO

CHICO-NAZARIO, J.

In reviewing rape cases, this Court has been guided by the following well-established principles: (a) an accusation of rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; (b) due to the nature of the crime of rape where only two persons are usually involved, the testimony of the private complainant must 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 for the defense.[13]

GR No. 178540

2008-06-27

PEOPLE v. ALEJANDRO SORILA

YNARES-SATIAGO, J.

Positive and categorical assertions of a witness prevail over bare denial,[21] which is a negative and self serving evidence. It cannot be given greater weight than the testimony of credible witnesses who testified on affirmative matters. Between the positive declarations of the prosecution witnesses and the negative statements of the accused, the former deserve more credence."[22] To merit credibility, denial must be buttressed by strong evidence of non-culpability,[23] which is lacking in the instant case. Furthermore, settled is the rule that when there is no evidence to show any dubious reason or improper motive why the prosecution witnesses should testify falsely against the accused or implicate him in a serious offense, their testimonies deserve full faith and credit.[24]

GR Nos. 152592-93

2004-02-13

PEOPLE v. JOURIEL DIMACUHA Y CASAO

YNARES-SATIAGO, J.

The trial court awarded P80,000.00 as actual damages despite absence of competent proof as required by Article 2199 of the Civil Code. To be entitled to actual damages, it is necessary to prove the actual amount of loss with a reasonable degree of certainty, premised upon competent proof and on the best evidence available to the injured party.[19] The award of P80,000.00 as actual damages therefore has no legal basis and must be deleted.

GR No. 152183

2004-01-22

PEOPLE v. NELSON GUAMBOR

YNARES-SATIAGO, J.

Nonetheless, in rape cases, the essential elements to be proved by the prosecution are the sexual congress without the victim's consent; that the sexual assault was committed using force or intimidation, or that it was committed against a woman deprived of reason or otherwise unconscious.[10] In this case, the trial court satisfactorily established that rape was committed using force and intimidation.

GR No. 146859

2004-01-20

PEOPLE v. RAUL OBRIQUE Y ANTONIO

AZCUNA, J.

In deciding rape cases, we are guided by the following well-established principles: (a) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, even if innocent, to disprove; (b) due to the 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 (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 for the defense.[37]

	GR No. 193169 2015-04-06	ROGELIO ROQUE v. PEOPLE DEL CASTILLO, J.
Besides, findings of facts of the RTC, its calibration of the testimonial evidence, its assessment of the probative weight thereof, as well as its conclusions anchored on the said findings, are accorded high respect if not conclusive effect when affirmed by the CA,[14] as in this case. After all, the RTC "had the opportunity to observe the witnesses on the stand and detect if they were telling the truth."[15] "To [thus] accord with the established doctrine of finality and bindingness of the trial court's findings of fact, [the Court shall] not disturb [the] findings of fact of the RTC, particularly after their affirmance by the CA"[16] as petitioner was not able to sufficiently establish any extraordinary circumstance which merits a departure from the said doctrine.[17]
	GR No. 179935 2010-04-19	PEOPLE v. ROGELIO ASIS Y LACSON DEL CASTILLO, J.
We are likewise not swayed by appellant's assertion that "AAA" filed the rape charges against him because he disallowed her to work in Manila. This claim is not only unsubstantiated, but likewise unworthy of belief. As aptly held by the trial court, it strains credulity that the victim would concoct a tale of rape against her own father, allow an examination of her private parts and subject herself to a public trial simply because she was not allowed to work in Manila. We have consistently held 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 show that rape was committed.[30]
	GR No. 181255 2009-10-16	PEOPLE v. ERNESTO PILI CHICO-NAZARIO, J.
crime of rape where only two persons are usually involved, the testimony of the private complainant must 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 for the defense.[23] It is well-established that when a woman says that she has been raped, she says, in effect, all that is necessary to show that she has indeed been raped.[24] A victim of rape would not come out in the open if her motive were anything other than to obtain
	GR No. 179714 2009-10-02	PEOPLE v. RODOLFO LOPEZ PERALTA, J.
This Court has repeatedly held that the evaluation of the testimony of the witnesses by the trial court is accorded the highest respect on appeal, because the court below had the opportunity to observe the witnesses on the stand and detect if they were telling the truth. This assessment is binding upon the appellate court in the absence of a clear showing that it was reached arbitrarily, or that the trial court plainly overlooked certain facts of substance or value that, if considered, might affect the result of the case.[21]
	GR No. 179714 2009-10-02	PEOPLE v. RODOLFO LOPEZ PERALTA, J.
For his defense, appellant Lopez merely denied committing the crime and even pointed an accusatory finger to the six-year-old brother of the victim, whom the former allegedly saw fingering the same victim. However, it is a time-honored principle that the positive and categorical assertions of a witness generally prevail over bare denials. Affirmative testimony from a credible witness is stronger and more trustworthy than a bare self-serving testimony.[29]
	GR No. 184791 2009-04-16	PEOPLE v. PEDRO NOGPO CHICO-NAZARIO, J.
In reviewing rape cases, this Court has been guided by the following well-established principles: (a) an accusation of rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; (b) due to the nature of the crime of rape where only two persons are usually involved, the testimony of the private complainant must 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 for the defense.[13]
	GR No. 178540 2008-06-27	PEOPLE v. ALEJANDRO SORILA YNARES-SATIAGO, J.
Positive and categorical assertions of a witness prevail over bare denial,[21] which is a negative and self serving evidence. It cannot be given greater weight than the testimony of credible witnesses who testified on affirmative matters. Between the positive declarations of the prosecution witnesses and the negative statements of the accused, the former deserve more credence."[22] To merit credibility, denial must be buttressed by strong evidence of non-culpability,[23] which is lacking in the instant case. Furthermore, settled is the rule that when there is no evidence to show any dubious reason or improper motive why the prosecution witnesses should testify falsely against the accused or implicate him in a serious offense, their testimonies deserve full faith and credit.[24]
	GR Nos. 152592-93 2004-02-13	PEOPLE v. JOURIEL DIMACUHA Y CASAO YNARES-SATIAGO, J.
The trial court awarded P80,000.00 as actual damages despite absence of competent proof as required by Article 2199 of the Civil Code. To be entitled to actual damages, it is necessary to prove the actual amount of loss with a reasonable degree of certainty, premised upon competent proof and on the best evidence available to the injured party.[19] The award of P80,000.00 as actual damages therefore has no legal basis and must be deleted.
	GR No. 152183 2004-01-22	PEOPLE v. NELSON GUAMBOR YNARES-SATIAGO, J.
Nonetheless, in rape cases, the essential elements to be proved by the prosecution are the sexual congress without the victim's consent; that the sexual assault was committed using force or intimidation, or that it was committed against a woman deprived of reason or otherwise unconscious.[10] In this case, the trial court satisfactorily established that rape was committed using force and intimidation.
	GR No. 146859 2004-01-20	PEOPLE v. RAUL OBRIQUE Y ANTONIO AZCUNA, J.
In deciding rape cases, we are guided by the following well-established principles: (a) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, even if innocent, to disprove; (b) due to the 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 (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 for the defense.[37]

PEOPLE v. CRISPIN T. RUALES