Lawyerly

GR No. 202020

2013-03-13

REYES, J.

The clear, consistent and spontaneous testimony of AAA unrelentingly established that Pielago inserted his right hand's forefinger into her vagina and anus while she and her younger brother, CCC, were in his custody. Being a child of tender years, her failure to resist or struggle while Pielago molested her would all the more prove how she felt intimidated by her "Kuya". Furthermore, Pielago's bare denial cannot exculpate him from the criminal charge. It is well-settled that denial, just like alibi, cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[22] Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crime attributed to him.[23]

GR No. 201587

2012-11-14

PEOPLE v. VICTOR LANSANGAN

REYES, J.

The denial of Lansangan cannot exculpate him from the criminal charge. It is well-settled that denial, just like alibi, cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[16] Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crime attributed to him.[17] Apparently, in the instant case, Lansangan failed to impute any ill motive on the part of the prosecution witnesses, particularly XXX, that would have impelled her to testify falsely against him. Thus, it was held in People v. Agcanas:[18]

GR No. 199264

2012-10-24

PEOPLE v. NOEL T. LAURINO

REYES, J.

At any rate, settled is the rule that alibi and denial cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[13] We thus ruled in People v. Agcanas:[14]

GR No. 194379

2011-06-01

PEOPLE v. FELICIANO 'SAYSOT' CIAS

VELASCO JR., J.

(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 person accused, though innocent, to disprove the charge; (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 of the prosecution must stand or fall on its own merit, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[29]

GR No. 194259

2011-03-06

PEOPLE v. JIMMY ALVERIO

VELASCO JR., J.

In People v. Malate,[27] We reiterated the principles with which courts are guided in determining the guilt or innocence of the accused in rape cases, viz: x x x (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 person accused, though innocent, to disprove the charge; (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 of the prosecution must stand or fall on its own merit, and cannot be allowed to draw strength from the weakness of the evidence for the defense.

GR No. 194259

2011-03-06

PEOPLE v. JIMMY ALVERIO

VELASCO JR., J.

Moreover, in that same case, this Court held that "in cases involving the prosecution for forcible rape x x x corroboration of the victim's testimony is not a necessary condition to a conviction for rape where the victim's testimony is credible, or clear and convincing or sufficient to prove the elements of the offense beyond a reasonable doubt."[28] As such, appellate courts generally do not disturb the findings of the trial court with regard to the assessment of the credibility of witnesses,[29] the reason being that the trial court has the "unique opportunity to observe the witnesses first hand and note their demeanor, conduct and attitude under grilling examination."[30] More importantly, courts generally give full credence to the testimony of a complainant for rape, especially one who is only a minor.[31]

GR No. 183829

2010-09-06

PEOPLE v. PATERNO LASANAS

CARPIO MORALES, J.

It need not be underlined that the weight and sufficiency of evidence are determined by the credibility, nature, and quality of the testimony.[20] That explains why an accused in rape cases may be convicted solely on the basis of the uncorroborated testimony of the victim where such testimony is clear, positive, convincing and consistent with human nature and the normal course of things,[21] as in AAA's testimony.

GR No. 188315

2010-08-25

PEOPLE v. ISIDRO FLORES Y LAGUA

PEREZ, J.

Both the trial court and the appellate court found AAA's testimony credible. The RTC considered it "straightforward and consistent on material points," while the Court of Appeals described it as "spontaneous, forthright, clear and free-from-serious contradictions." Well-entrenched is the legal precept that when the "culpability or innocence of an accused hinges on the issue of the credibility of witnesses, the findings of fact of the Court of Appeals affirming those of the trial court, when duly supported by sufficient and convincing evidence, must be accorded the highest respect, even finality, by this Court and are not to be disturbed on appeal."[31] We see no reason in this case to depart from the principle. Moreover, we give due deference to the trial court's assessment of AAA's credibility, having had the opportunity to witnesses firsthand and note her demeanor, conduct, and attitude under grilling examination.[32]

GR No. 186119

2009-10-27

PEOPLE v. PABLO LUSABIO

CHICO-NAZARIO, J.

Such inconsistency, which we consider to be minor or trivial, will not impair Doris Labini's credibility. This Court has ruled that inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect the substance of their declarations, their veracity, or the weight of their testimonies. Such minor flaws may even enhance the worth of a testimony, for they guard against memorized falsities.[37] Trivial inconsistencies do not rock the pedestal upon which the credibility of the witness rests, but enhance credibility, as they manifest spontaneity and lack of scheming.[38] It is not to be expected that the witness will be able to remember every single detail of an incident with perfect or total recall.[39] Furthermore, it is to be noted that Tomasito de los Santos is one of the accused in the murder case, while Doris Labini is a prosecution witness. We, therefore, cannot simply discredit Doris Labini because of a statement coming from the mouth of an accused.

GR No. 186129

2009-08-04

PEOPLE v. JESUS PARAGAS CRUZ

VELASCO JR., J.

Cruz's final argument likewise fails to convince this Court. He relies on as alibi his presence in Multinational Village in Parañaque City conducting a land survey at the time of the rape incident. To sustain such an alibi, the defense must establish the physical impossibility for the accused to be present at the scene of the crime at the time of its commission.[17] True it is that his story was corroborated by additional witnesses. These testimonies, however, did not show the physical impossibility of Cruz to be present at AAA's home when she was raped. Even if Cruz conducted the land survey on the same day, he could have very easily committed the rape as he was in the same city as AAA.

	GR No. 202020 2013-03-13	MIKE ALVIN PIELAGO Y ROS v. PEOPLE REYES, J.
The clear, consistent and spontaneous testimony of AAA unrelentingly established that Pielago inserted his right hand's forefinger into her vagina and anus while she and her younger brother, CCC, were in his custody. Being a child of tender years, her failure to resist or struggle while Pielago molested her would all the more prove how she felt intimidated by her "Kuya". Furthermore, Pielago's bare denial cannot exculpate him from the criminal charge. It is well-settled that denial, just like alibi, cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[22] Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crime attributed to him.[23]
	GR No. 201587 2012-11-14	PEOPLE v. VICTOR LANSANGAN REYES, J.
The denial of Lansangan cannot exculpate him from the criminal charge. It is well-settled that denial, just like alibi, cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[16] Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the victim of the identity and involvement of appellant in the crime attributed to him.[17] Apparently, in the instant case, Lansangan failed to impute any ill motive on the part of the prosecution witnesses, particularly XXX, that would have impelled her to testify falsely against him. Thus, it was held in People v. Agcanas:[18]
	GR No. 199264 2012-10-24	PEOPLE v. NOEL T. LAURINO REYES, J.
At any rate, settled is the rule that alibi and denial cannot prevail over the positive and categorical testimony and identification of an accused by the complainant.[13] We thus ruled in People v. Agcanas:[14]
	GR No. 194379 2011-06-01	PEOPLE v. FELICIANO 'SAYSOT' CIAS VELASCO JR., J.
(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 person accused, though innocent, to disprove the charge; (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 of the prosecution must stand or fall on its own merit, and cannot be allowed to draw strength from the weakness of the evidence for the defense.[29]
	GR No. 194259 2011-03-06	PEOPLE v. JIMMY ALVERIO VELASCO JR., J.
In People v. Malate,[27] We reiterated the principles with which courts are guided in determining the guilt or innocence of the accused in rape cases, viz: x x x (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 person accused, though innocent, to disprove the charge; (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 of the prosecution must stand or fall on its own merit, and cannot be allowed to draw strength from the weakness of the evidence for the defense.
	GR No. 194259 2011-03-06	PEOPLE v. JIMMY ALVERIO VELASCO JR., J.
Moreover, in that same case, this Court held that "in cases involving the prosecution for forcible rape x x x corroboration of the victim's testimony is not a necessary condition to a conviction for rape where the victim's testimony is credible, or clear and convincing or sufficient to prove the elements of the offense beyond a reasonable doubt."[28] As such, appellate courts generally do not disturb the findings of the trial court with regard to the assessment of the credibility of witnesses,[29] the reason being that the trial court has the "unique opportunity to observe the witnesses first hand and note their demeanor, conduct and attitude under grilling examination."[30] More importantly, courts generally give full credence to the testimony of a complainant for rape, especially one who is only a minor.[31]
	GR No. 183829 2010-09-06	PEOPLE v. PATERNO LASANAS CARPIO MORALES, J.
It need not be underlined that the weight and sufficiency of evidence are determined by the credibility, nature, and quality of the testimony.[20] That explains why an accused in rape cases may be convicted solely on the basis of the uncorroborated testimony of the victim where such testimony is clear, positive, convincing and consistent with human nature and the normal course of things,[21] as in AAA's testimony.
	GR No. 188315 2010-08-25	PEOPLE v. ISIDRO FLORES Y LAGUA PEREZ, J.
Both the trial court and the appellate court found AAA's testimony credible. The RTC considered it "straightforward and consistent on material points," while the Court of Appeals described it as "spontaneous, forthright, clear and free-from-serious contradictions." Well-entrenched is the legal precept that when the "culpability or innocence of an accused hinges on the issue of the credibility of witnesses, the findings of fact of the Court of Appeals affirming those of the trial court, when duly supported by sufficient and convincing evidence, must be accorded the highest respect, even finality, by this Court and are not to be disturbed on appeal."[31] We see no reason in this case to depart from the principle. Moreover, we give due deference to the trial court's assessment of AAA's credibility, having had the opportunity to witnesses firsthand and note her demeanor, conduct, and attitude under grilling examination.[32]
	GR No. 186119 2009-10-27	PEOPLE v. PABLO LUSABIO CHICO-NAZARIO, J.
Such inconsistency, which we consider to be minor or trivial, will not impair Doris Labini's credibility. This Court has ruled that inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect the substance of their declarations, their veracity, or the weight of their testimonies. Such minor flaws may even enhance the worth of a testimony, for they guard against memorized falsities.[37] Trivial inconsistencies do not rock the pedestal upon which the credibility of the witness rests, but enhance credibility, as they manifest spontaneity and lack of scheming.[38] It is not to be expected that the witness will be able to remember every single detail of an incident with perfect or total recall.[39] Furthermore, it is to be noted that Tomasito de los Santos is one of the accused in the murder case, while Doris Labini is a prosecution witness. We, therefore, cannot simply discredit Doris Labini because of a statement coming from the mouth of an accused.
	GR No. 186129 2009-08-04	PEOPLE v. JESUS PARAGAS CRUZ VELASCO JR., J.
Cruz's final argument likewise fails to convince this Court. He relies on as alibi his presence in Multinational Village in Parañaque City conducting a land survey at the time of the rape incident. To sustain such an alibi, the defense must establish the physical impossibility for the accused to be present at the scene of the crime at the time of its commission.[17] True it is that his story was corroborated by additional witnesses. These testimonies, however, did not show the physical impossibility of Cruz to be present at AAA's home when she was raped. Even if Cruz conducted the land survey on the same day, he could have very easily committed the rape as he was in the same city as AAA.

PEOPLE v. JESSIE MALATE Y CAÑETE