Lawyerly

GR No. 209587

2015-09-23

VILLARAMA, JR., J.

We find the testimony of AAA sufficient to establish the element of carnal knowledge. We note that the RTC described the testimony of AAA as positive, credible, natural and convincing.[9] The 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. Youth and immaturity are generally badges of truth. 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.[10]

GR No. 202122

2014-01-15

PEOPLE v. BERNABE PAREJA Y CRUZ

LEONARDO-DE CASTRO, J.

In People v. Perez,[43] this Court aptly held: 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. Youth and immaturity are generally badges of truth. 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. (Citations omitted.)

GR No. 191253

2013-08-28

PEOPLE v. APOLINARIO MANALILI Y JOSE

PEREZ, J.

Manalili contends that AAA's testimony is not sufficient to convict him because the identity of the accused as the perpetrator of the crime was not positively established. We find such argument untenable. Jurisprudence is instructive that identification of an accused by his voice has been accepted particularly in cases where, such as in this case, the witness has known the malefactor personally for so long and so intimately.[24] This Court has opined that once a person has gained familiarity with another, identification becomes quite an easy task even from a considerable distance.[25] Furthermore, settled is the rule that the testimony of a single witness may be sufficient to produce a conviction, if the same appears to be trustworthy and reliable. If credible and convincing, that alone would be sufficient to convict the accused.[26] No law or rule requires the corroboration of the testimony of a single witness in a rape case. [27]

GR No. 183827

2012-11-12

PEOPLE v. ENERIO ENDING Y ONYONG

DEL CASTILLO, J.

The defense of appellant is anchored on denial and alibi which do not impress belief. As often stressed, "[m]ere denial, if unsubstantiated by clear and convincing evidence, has no weight in law and cannot be given greater evidentiary value than the positive testimony of a rape victim."[19] In this case, appellant's testimony, particularly his denial, was not substantiated by clear and convincing evidence. Also, for his alibi to prosper, appellant must establish that he was not at the locus delicti at the time the offense was committed and that it was physically impossible for him to be at the scene of the crime at the time of its commission.[20] Appellant failed to establish these elements. The fact that "AAA" was living with her grandparents did not preclude the possibility that appellant was present at the crime scenes during their commission. Appellant himself admitted that the distance between his residence and that of "AAA's" grandparents is only approximately 7½ kilometers and which can be traversed by riding a pedicab in less than 30 minutes.[21] In other words, it was not physically impossible for appellant to have been at the situs of the crimes during the dates when the separate acts of rape were committed. Moreover, it has been invariably ruled that alibi cannot prevail over the positive identification of the accused. Here, appellant was positively identified by "AAA" as the perpetrator of the crimes without showing any dubious reason or fiendish motive on her part to falsely charge him. The contention of appellant that "AAA" was motivated by hatred because he prevented her from having a boyfriend is unconvincing. There is nothing novel in such a contrived defense. "Motives such as resentment, hatred or revenge have never swayed this Court from giving full credence to the testimony of a rape victim."[22] It is a jurisprudentially conceded rule that "[i]t is against human nature for a young girl to fabricate a story that would expose herself as well as her family to a lifetime of shame, especially when her charge could mean the death or lifetime imprisonment of her own father."[23]

GR No. 195239

2012-03-07

PEOPLE v. BEN RUBIO Y ACOSTA

VELASCO JR., J.

When it comes to credibility, the trial court's assessment deserves great weight, and is even conclusive and binding, if not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence.[14] The reason is obvious. Having the full opportunity to observe directly the witnesses' deportment and manner of testifying, the trial court is in a better position than the appellate court to evaluate testimonial evidence properly.[15] As this Court held in People v. Gabrino: We have held time and again that "the trial court's assessment of the credibility of a witness is entitled to great weight, sometimes even with finality." As We have reiterated in the recent People v. Combate, where there is no showing that the trial court overlooked or misinterpreted some material facts or that it gravely abused its discretion, then We do not disturb and interfere with its assessment of the facts and the credibility of the witnesses. This is clearly because the judge in the trial court was the one who personally heard the accused and the witnesses, and observed their demeanor as well as the manner in which they testified during trial. Accordingly, the trial court, or more particularly, the RTC in this case, is in a better position to assess and weigh the evidence presented during trial.[16]

GR No. 188897

2011-06-06

PEOPLE v. IRENO BONAAGUA Y BERCE

PERALTA, J.

This Court, however, finds the arguments raised by Ireno untenable. To determine the innocence or guilt of the accused in rape cases, 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. [17]

GR No. 185616

2010-11-24

PEOPLE v. ARNEL MACAFE Y NABONG

BRION, 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 subjecting herself to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her. Youth and immaturity are generally badges of truth. 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 as serious as rape if what she claims is not true.[23]

GR No. 189092

2010-08-19

PEOPLE v. MELVIN LOLOS

MENDOZA, J.

The gravamen of the offense of rape is sexual congress with a woman by force and without consent. As provided in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[9]

GR No. 188569

2010-07-13

PEOPLE v. ROBERTO GARBIDA

VELASCO JR., J.

The voluntary submission of AAA, even if the Court were convinced that such is the case, to the sexual desires of accused-appellant will not relieve him of criminal liability. As she was 11 years old at the time, she could not give consent, and if she had indicated in any way to accused-appellant that she consented to having sexual intercourse with him, there is no reason for him, were he not morally depraved, to take advantage of her consent. Sexual congress with a girl under 12 years old is always rape.[11]

GR No. 186461

2010-07-05

PEOPLE v. SEVERIANO OGAN

VELASCO JR., J.

As provided for in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[21] The crime of statutory rape carries the penalty of reclusion perpetua unless attended by the qualifying circumstances defined under Article 266-B.[22]

GR No. 187742

2010-04-20

PEOPLE v. CRIZALDO PACHECO Y VILLANUEVA

VELASCO JR., J.

The Revised Penal Code defines statutory rape as sexual intercourse with a girl below 12 years old. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age.[8]

GR No. 175317

2009-10-02

PEOPLE v. CRISTINO CAÑADA

BRION, J.

AAA's testimony strikes us to be clear, convincing and credible. It was furthermore corroborated by the medico-legal report and testimony of Dr. Mon. We note that at the initial phases of AAA's testimony, she broke down on the witness stand when the prosecution started to ask questions dealing directly with the incident. This, to our mind, is an eloquent and moving indicium of the truth of her allegations. We additionally do not see from the records any indication that AAA's testimony should be seen in a suspicious light. In fact, AAA testified that the appellant was good to her and treated her like a daughter. We have held, time and again, that testimonies of rape victims who are young and immature, as in this case, deserve full credence considering that no young woman, especially one of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter testify about her ordeal in a public trial, if she had not been motivated by the desire to obtain justice for the wrong committed against her.[56]

	GR No. 209587 2015-09-23	PEOPLE v. JOEL 'ANJOY' BUCA VILLARAMA, JR., J.
We find the testimony of AAA sufficient to establish the element of carnal knowledge. We note that the RTC described the testimony of AAA as positive, credible, natural and convincing.[9] The 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. Youth and immaturity are generally badges of truth. 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.[10]
	GR No. 202122 2014-01-15	PEOPLE v. BERNABE PAREJA Y CRUZ LEONARDO-DE CASTRO, J.
In People v. Perez,[43] this Court aptly held: 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. Youth and immaturity are generally badges of truth. 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. (Citations omitted.)
	GR No. 191253 2013-08-28	PEOPLE v. APOLINARIO MANALILI Y JOSE PEREZ, J.
Manalili contends that AAA's testimony is not sufficient to convict him because the identity of the accused as the perpetrator of the crime was not positively established. We find such argument untenable. Jurisprudence is instructive that identification of an accused by his voice has been accepted particularly in cases where, such as in this case, the witness has known the malefactor personally for so long and so intimately.[24] This Court has opined that once a person has gained familiarity with another, identification becomes quite an easy task even from a considerable distance.[25] Furthermore, settled is the rule that the testimony of a single witness may be sufficient to produce a conviction, if the same appears to be trustworthy and reliable. If credible and convincing, that alone would be sufficient to convict the accused.[26] No law or rule requires the corroboration of the testimony of a single witness in a rape case. [27]
	GR No. 183827 2012-11-12	PEOPLE v. ENERIO ENDING Y ONYONG DEL CASTILLO, J.
The defense of appellant is anchored on denial and alibi which do not impress belief. As often stressed, "[m]ere denial, if unsubstantiated by clear and convincing evidence, has no weight in law and cannot be given greater evidentiary value than the positive testimony of a rape victim."[19] In this case, appellant's testimony, particularly his denial, was not substantiated by clear and convincing evidence. Also, for his alibi to prosper, appellant must establish that he was not at the locus delicti at the time the offense was committed and that it was physically impossible for him to be at the scene of the crime at the time of its commission.[20] Appellant failed to establish these elements. The fact that "AAA" was living with her grandparents did not preclude the possibility that appellant was present at the crime scenes during their commission. Appellant himself admitted that the distance between his residence and that of "AAA's" grandparents is only approximately 7½ kilometers and which can be traversed by riding a pedicab in less than 30 minutes.[21] In other words, it was not physically impossible for appellant to have been at the situs of the crimes during the dates when the separate acts of rape were committed. Moreover, it has been invariably ruled that alibi cannot prevail over the positive identification of the accused. Here, appellant was positively identified by "AAA" as the perpetrator of the crimes without showing any dubious reason or fiendish motive on her part to falsely charge him. The contention of appellant that "AAA" was motivated by hatred because he prevented her from having a boyfriend is unconvincing. There is nothing novel in such a contrived defense. "Motives such as resentment, hatred or revenge have never swayed this Court from giving full credence to the testimony of a rape victim."[22] It is a jurisprudentially conceded rule that "[i]t is against human nature for a young girl to fabricate a story that would expose herself as well as her family to a lifetime of shame, especially when her charge could mean the death or lifetime imprisonment of her own father."[23]
	GR No. 195239 2012-03-07	PEOPLE v. BEN RUBIO Y ACOSTA VELASCO JR., J.
When it comes to credibility, the trial court's assessment deserves great weight, and is even conclusive and binding, if not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence.[14] The reason is obvious. Having the full opportunity to observe directly the witnesses' deportment and manner of testifying, the trial court is in a better position than the appellate court to evaluate testimonial evidence properly.[15] As this Court held in People v. Gabrino: We have held time and again that "the trial court's assessment of the credibility of a witness is entitled to great weight, sometimes even with finality." As We have reiterated in the recent People v. Combate, where there is no showing that the trial court overlooked or misinterpreted some material facts or that it gravely abused its discretion, then We do not disturb and interfere with its assessment of the facts and the credibility of the witnesses. This is clearly because the judge in the trial court was the one who personally heard the accused and the witnesses, and observed their demeanor as well as the manner in which they testified during trial. Accordingly, the trial court, or more particularly, the RTC in this case, is in a better position to assess and weigh the evidence presented during trial.[16]
	GR No. 188897 2011-06-06	PEOPLE v. IRENO BONAAGUA Y BERCE PERALTA, J.
This Court, however, finds the arguments raised by Ireno untenable. To determine the innocence or guilt of the accused in rape cases, 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. [17]
	GR No. 185616 2010-11-24	PEOPLE v. ARNEL MACAFE Y NABONG BRION, 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 subjecting herself to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her. Youth and immaturity are generally badges of truth. 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 as serious as rape if what she claims is not true.[23]
	GR No. 189092 2010-08-19	PEOPLE v. MELVIN LOLOS MENDOZA, J.
The gravamen of the offense of rape is sexual congress with a woman by force and without consent. As provided in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[9]
	GR No. 188569 2010-07-13	PEOPLE v. ROBERTO GARBIDA VELASCO JR., J.
The voluntary submission of AAA, even if the Court were convinced that such is the case, to the sexual desires of accused-appellant will not relieve him of criminal liability. As she was 11 years old at the time, she could not give consent, and if she had indicated in any way to accused-appellant that she consented to having sexual intercourse with him, there is no reason for him, were he not morally depraved, to take advantage of her consent. Sexual congress with a girl under 12 years old is always rape.[11]
	GR No. 186461 2010-07-05	PEOPLE v. SEVERIANO OGAN VELASCO JR., J.
As provided for in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[21] The crime of statutory rape carries the penalty of reclusion perpetua unless attended by the qualifying circumstances defined under Article 266-B.[22]
	GR No. 187742 2010-04-20	PEOPLE v. CRIZALDO PACHECO Y VILLANUEVA VELASCO JR., J.
The Revised Penal Code defines statutory rape as sexual intercourse with a girl below 12 years old. The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age.[8]
	GR No. 175317 2009-10-02	PEOPLE v. CRISTINO CAÑADA BRION, J.
AAA's testimony strikes us to be clear, convincing and credible. It was furthermore corroborated by the medico-legal report and testimony of Dr. Mon. We note that at the initial phases of AAA's testimony, she broke down on the witness stand when the prosecution started to ask questions dealing directly with the incident. This, to our mind, is an eloquent and moving indicium of the truth of her allegations. We additionally do not see from the records any indication that AAA's testimony should be seen in a suspicious light. In fact, AAA testified that the appellant was good to her and treated her like a daughter. We have held, time and again, that testimonies of rape victims who are young and immature, as in this case, deserve full credence considering that no young woman, especially one of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter testify about her ordeal in a public trial, if she had not been motivated by the desire to obtain justice for the wrong committed against her.[56]

PEOPLE v. JOSE PEREZ