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GR No. 188352

2010-09-01

MENDOZA, J.

The variance in AAA's Salaysay and her oral testimony during direct examination was patently borne out of a young mind's casual indifference to legal documents and its implications. Again, AAA was a mere 12-year-old lass who, in the eyes of the law, was not mature enough to exercise diligence and meticulousness in the conduct of the complaint she filed. Surely, this Court cannot fault her for her puerile approach to legal matters. More importantly, this inconsistency does not relate to the facts constitutive of the crime charged. The accused cannot be allowed to take advantage of this lapse. The circumstances of the rape incident are definitely not altered by whatever it was that her mother asked her to buy on that fateful night. For acquittal to lie, the discrepancies should touch on significant facts which are crucial to the guilt or innocence of an accused.[29]

GR Nos. 130493-98

2004-04-28

PEOPLE v. ROGELIO LAYUGAN Y FURUC

SANDOVAL-GUTIERREZ, J.

We have scrutinized with great caution Evelyn's testimony, fully mindful of the well-established guiding principles in the adjudication of rape cases that an accusation of rape can be made with facility, but more difficult for the accused to disprove it;[19] hence, the victim's testimony must not be received with precipitate credulity.[20]

GR No. 145305

2003-06-26

PEOPLE v. REDANTE SANTOS Y CRUZ

CARPIO, J.

Appellant also asserted that he could not have raped Danly on 9 April 1998 as they were actually in Marikina and not in Pasig on this date and he had witnesses to prove such fact.[29] Danly refuted this, stating that they were in Marikina on 7 April 1998 and that they were in Pasig on 9 April 1998.[30] Even if appellant and Danly were in Marikina on 9 April 1998, such fact does not preclude the commission of the crime of rape. It is sufficient that the information alleges that the crime was committed on or about a specific date since time is not a material element of rape.[31]

GR No. 144082-83

2002-04-18

PEOPLE v. FAUSTINO DULAY

YNARES-SANTIAGO, J.

Guided by the foregoing principles, we have carefully examined the testimony of Princess Olimpo and found no error on the trial court's giving credence to her declarations. Complainant, who was only 10 years old when she testified, was candid and straightforward in her version of the facts. She was not shown to have the shrewdness and callousness of a woman who would concoct such a story and endure physical examination and public trial if her story were untrue. The Court has 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.[12] Moreover, the records show that the complainant was crying when she testified. In a number of cases, this has been held to be evidence of truthfulness of the rape charge with the verity born out of human nature and experience.[13]

GR Nos. 140218-23

2002-02-13

PEOPLE v. CARLOS ESCAÑO

PER CURIAM

Be that as it may, what is important is that the prosecution was able to prove that accused-appellant had carnal knowledge of the complainant five times without her consent.[28] Any discrepancy between the dates given during the preliminary examination and those given during the trial concerns minor matters and does not detract from the credibility of complainant Mergie. As we have ruled in other cases,[29] discrepancies in details which are irrelevant to the elements of the crime, such as the exact time of the commission of the crime, are not grounds for acquittal.

GR Nos. 139959-60

2001-11-22

PEOPLE v. DEOGRACIAS BURGOS Y ARSITE

MENDOZA, J.

In adjudging rape cases, the Court is guided by the following 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) in view of the nature of the crime in which only two persons are 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 of the defense.[16] It has been held that the accused may be convicted solely on the testimony of the victim, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things.[17]

GR Nos. 139959-60

2001-11-22

PEOPLE v. DEOGRACIAS BURGOS Y ARSITE

MENDOZA, J.

In adjudging rape cases, the Court is guided by the following 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) in view of the nature of the crime in which only two persons are 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 of the defense.[16] It has been held that the accused may be convicted solely on the testimony of the victim, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things.[17]

GR Nos. 139959-60

2001-11-22

PEOPLE v. DEOGRACIAS BURGOS Y ARSITE

MENDOZA, J.

We have held that the trial court's assessment of the credibility of witnesses is accorded great respect because of its opportunity to hear their testimonies and observe their demeanor and manner of testifying.[26] We do not find any reason to disturb the findings of the trial court since it did not manifestly overlook any fact which would have altered the result of the case.

GR Nos. 139959-60

2001-11-22

PEOPLE v. DEOGRACIAS BURGOS Y ARSITE

MENDOZA, J.

The award of P30,000.00 as moral damages for each count of rape should be modified, however, and increased to P50,000.00 for each count or a total of P100,000.00 in accordance with current jurisprudence.[31]

GR Nos. 142602-05

2001-10-03

PEOPLE v. BONIFACIO ARIOLA

MENDOZA, J.

Accused-appellant argues that complainant's testimony should not be given credence because she could not give the exact dates when accused-appellant allegedly raped her. This argument has no merit. The exact date of the commission of the rape is not an essential element of the crime. What is important is that the prosecution was able to prove that accused-appellant had carnal knowledge of the victim without her consent.[18] In these cases, Maribel's testimony established that accused-appellant forced her to have sex with him for four consecutive nights in December 1994 when she was alone with him in their house. It bears emphasis that accused-appellant himself admitted that he was left alone in the house with Maribel on December 16 to 19, 1994.[19]

GR No. 139180

2001-07-31

PEOPLE v. ROLANDO RIVERA

MENDOZA, J.

Complainant's failure to remember the date of the commission of the rape cannot be taken against her. The exact date when complainant was sexually abused is not an essential element of the crime of rape.[52] Nor does the fact that complainant was sleeping beside her sister when the rape occurred detract from her credibility. The possibility of rape is not negated by the fact that the presence of even the whole family of the accused inside the same room produced the possibility of discovery. For rape to be committed, it is not necessary for the place to be ideal, for rapists respect neither time nor place for carrying out their evil designs.[53]

GR No. 141512

2001-04-16

CRESENCIO S. MENDOZA v. PEOPLE

MENDOZA, J.

First. In adjudging rape cases, this Court is guided by the following principles: (a) an accusation of rape is difficult to prove but more difficult for the person accused, though innocent, to disprove; (b) in view of the nature of the crime in which only two persons are 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 merits and cannot be allowed to draw strength from the weakness of the evidence for the defense.[21] As in most cases of sexual aggression and molestation, the resolution of the present appeal hinges on the issue of credibility of the witnesses of the parties. On this point, we think the Court of Appeals correctly sustained the decision of the trial court which found the testimony of the victim and the other witnesses for the prosecution worthy of belief. The trial court's assessment of the credibility of witnesses should be accorded great respect because of its opportunity to hear their testimonies and observe their demeanor and manner of testifying.[22] Indeed, we find Eloisa's testimony, both on direct and cross-examination to be clear and spontaneous, and we are persuaded that she was telling the truth. Eloisa narrated in detail how petitioner had tried to rape her on or about May 15, 1995:[23]

	GR No. 188352 2010-09-01	PEOPLE v. ROLLY DE GUZMAN MENDOZA, J.
The variance in AAA's Salaysay and her oral testimony during direct examination was patently borne out of a young mind's casual indifference to legal documents and its implications. Again, AAA was a mere 12-year-old lass who, in the eyes of the law, was not mature enough to exercise diligence and meticulousness in the conduct of the complaint she filed. Surely, this Court cannot fault her for her puerile approach to legal matters. More importantly, this inconsistency does not relate to the facts constitutive of the crime charged. The accused cannot be allowed to take advantage of this lapse. The circumstances of the rape incident are definitely not altered by whatever it was that her mother asked her to buy on that fateful night. For acquittal to lie, the discrepancies should touch on significant facts which are crucial to the guilt or innocence of an accused.[29]
	GR Nos. 130493-98 2004-04-28	PEOPLE v. ROGELIO LAYUGAN Y FURUC SANDOVAL-GUTIERREZ, J.
We have scrutinized with great caution Evelyn's testimony, fully mindful of the well-established guiding principles in the adjudication of rape cases that an accusation of rape can be made with facility, but more difficult for the accused to disprove it;[19] hence, the victim's testimony must not be received with precipitate credulity.[20]
	GR No. 145305 2003-06-26	PEOPLE v. REDANTE SANTOS Y CRUZ CARPIO, J.
Appellant also asserted that he could not have raped Danly on 9 April 1998 as they were actually in Marikina and not in Pasig on this date and he had witnesses to prove such fact.[29] Danly refuted this, stating that they were in Marikina on 7 April 1998 and that they were in Pasig on 9 April 1998.[30] Even if appellant and Danly were in Marikina on 9 April 1998, such fact does not preclude the commission of the crime of rape. It is sufficient that the information alleges that the crime was committed on or about a specific date since time is not a material element of rape.[31]
	GR No. 144082-83 2002-04-18	PEOPLE v. FAUSTINO DULAY YNARES-SANTIAGO, J.
Guided by the foregoing principles, we have carefully examined the testimony of Princess Olimpo and found no error on the trial court's giving credence to her declarations. Complainant, who was only 10 years old when she testified, was candid and straightforward in her version of the facts. She was not shown to have the shrewdness and callousness of a woman who would concoct such a story and endure physical examination and public trial if her story were untrue. The Court has 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.[12] Moreover, the records show that the complainant was crying when she testified. In a number of cases, this has been held to be evidence of truthfulness of the rape charge with the verity born out of human nature and experience.[13]
	GR Nos. 140218-23 2002-02-13	PEOPLE v. CARLOS ESCAÑO PER CURIAM
Be that as it may, what is important is that the prosecution was able to prove that accused-appellant had carnal knowledge of the complainant five times without her consent.[28] Any discrepancy between the dates given during the preliminary examination and those given during the trial concerns minor matters and does not detract from the credibility of complainant Mergie. As we have ruled in other cases,[29] discrepancies in details which are irrelevant to the elements of the crime, such as the exact time of the commission of the crime, are not grounds for acquittal.
	GR Nos. 139959-60 2001-11-22	PEOPLE v. DEOGRACIAS BURGOS Y ARSITE MENDOZA, J.
In adjudging rape cases, the Court is guided by the following 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) in view of the nature of the crime in which only two persons are 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 of the defense.[16] It has been held that the accused may be convicted solely on the testimony of the victim, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things.[17]
	GR Nos. 139959-60 2001-11-22	PEOPLE v. DEOGRACIAS BURGOS Y ARSITE MENDOZA, J.
In adjudging rape cases, the Court is guided by the following 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) in view of the nature of the crime in which only two persons are 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 of the defense.[16] It has been held that the accused may be convicted solely on the testimony of the victim, provided it is credible, natural, convincing, and consistent with human nature and the normal course of things.[17]
	GR Nos. 139959-60 2001-11-22	PEOPLE v. DEOGRACIAS BURGOS Y ARSITE MENDOZA, J.
We have held that the trial court's assessment of the credibility of witnesses is accorded great respect because of its opportunity to hear their testimonies and observe their demeanor and manner of testifying.[26] We do not find any reason to disturb the findings of the trial court since it did not manifestly overlook any fact which would have altered the result of the case.
	GR Nos. 139959-60 2001-11-22	PEOPLE v. DEOGRACIAS BURGOS Y ARSITE MENDOZA, J.
The award of P30,000.00 as moral damages for each count of rape should be modified, however, and increased to P50,000.00 for each count or a total of P100,000.00 in accordance with current jurisprudence.[31]
	GR Nos. 142602-05 2001-10-03	PEOPLE v. BONIFACIO ARIOLA MENDOZA, J.
Accused-appellant argues that complainant's testimony should not be given credence because she could not give the exact dates when accused-appellant allegedly raped her. This argument has no merit. The exact date of the commission of the rape is not an essential element of the crime. What is important is that the prosecution was able to prove that accused-appellant had carnal knowledge of the victim without her consent.[18] In these cases, Maribel's testimony established that accused-appellant forced her to have sex with him for four consecutive nights in December 1994 when she was alone with him in their house. It bears emphasis that accused-appellant himself admitted that he was left alone in the house with Maribel on December 16 to 19, 1994.[19]
	GR No. 139180 2001-07-31	PEOPLE v. ROLANDO RIVERA MENDOZA, J.
Complainant's failure to remember the date of the commission of the rape cannot be taken against her. The exact date when complainant was sexually abused is not an essential element of the crime of rape.[52] Nor does the fact that complainant was sleeping beside her sister when the rape occurred detract from her credibility. The possibility of rape is not negated by the fact that the presence of even the whole family of the accused inside the same room produced the possibility of discovery. For rape to be committed, it is not necessary for the place to be ideal, for rapists respect neither time nor place for carrying out their evil designs.[53]
	GR No. 141512 2001-04-16	CRESENCIO S. MENDOZA v. PEOPLE MENDOZA, J.
First. In adjudging rape cases, this Court is guided by the following principles: (a) an accusation of rape is difficult to prove but more difficult for the person accused, though innocent, to disprove; (b) in view of the nature of the crime in which only two persons are 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 merits and cannot be allowed to draw strength from the weakness of the evidence for the defense.[21] As in most cases of sexual aggression and molestation, the resolution of the present appeal hinges on the issue of credibility of the witnesses of the parties. On this point, we think the Court of Appeals correctly sustained the decision of the trial court which found the testimony of the victim and the other witnesses for the prosecution worthy of belief. The trial court's assessment of the credibility of witnesses should be accorded great respect because of its opportunity to hear their testimonies and observe their demeanor and manner of testifying.[22] Indeed, we find Eloisa's testimony, both on direct and cross-examination to be clear and spontaneous, and we are persuaded that she was telling the truth. Eloisa narrated in detail how petitioner had tried to rape her on or about May 15, 1995:[23]

PEOPLE v. ALBERTO GARCIA Y BOTON