Lawyerly

GR No. 200508

2013-09-04

MENDOZA, J.

Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they are lying.[27] [Italicization supplied]

GR No. 186461

2010-07-05

PEOPLE v. SEVERIANO OGAN

VELASCO JR., J.

It bears noting that both the trial and appellate courts did not specify what kind of damages was being awarded apart from civil indemnity.[35] In awarding damages, the trial court should state the factual bases of the award of these damages.[36] Thus, in rape cases, damages may refer to moral and exemplary, and these must be specified as these have different bases.[37]

GR No. 176742

2008-06-17

PEOPLE v. WENCESLAO ESPINO

CHICO-NAZARIO, J.

Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[43] The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[44]

GR No. 177749

2007-12-17

PEOPLE v. MANUEL AGUILAR

CHICO-NAZARIO, J.

Accordingly, the primordial consideration in a determination concerning the crime of rape is the credibility of complainant's testimony.[35] Time and again, we have held that when it comes to the issue of credibility of the victim or the prosecution witnesses, the findings of the trial courts carry great weight and respect and, generally, the appellate courts will not overturn the said findings unless the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which will alter the assailed decision or affect the result of the case.[36] This is so because trial courts are in the best position to ascertain and measure the sincerity and spontaneity of witnesses through their actual observation of the witnesses' manner of testifying, their demeanor and behavior in court.[37] Trial judges enjoy the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. Trial judges, therefore, can better determine if such witnesses are telling the truth, being in the ideal position to weigh conflicting testimonies. Again, unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected, for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[38] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[39]

GR No. 176633

2007-09-05

PEOPLE v. ARMANDO SAN ANTONIO

CHICO-NAZARIO, J.

Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" - all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they are lying.[42] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[43]

GR No. 171731

2006-08-11

PEOPLE v. JOVEN OCAMPO

YNARES-SANTIAGO, J.

In rape cases, courts are guided by the following principles: (1) to accuse a man of rape is easy, but to disprove it is difficult though the accused may be innocent; (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 merit and not be allowed to draw strength from the weakness of the evidence for the defense.[22]

GR NO. 166040

2006-04-26

NIEL F. LLAVE v. PEOPLE

CALLEJO, SR., J.

That petitioner ravished the victim not far from the street where residents passed by does not negate the act of rape committed by petitioner. Rape is not a respecter of time and place. The crime may be committed by the roadside and even in occupied premises.[79] The presence of people nearby does not deter rapists from committing the odious act.[80] In this case, petitioner was so daring that he ravished the private complainant near the house of Teofisto even as commuters passed by, impervious to the fact that a crime was being committed in their midst.

GR No. 134773

2004-06-29

PEOPLE v. AVELINO MABONGA Y BABON

SANDOVAL-GUTIERREZ, J.

Appellant also underscores the impossibility of committing rape in the presence of people, such as his wife and neighbors. But it is a common judicial experience that "the presence of people nearby does not deter rapists from committing their odious act. Rape can be committed even in places where people congregate, in parks, along the roadside, within school premises, inside a house where there are several occupants and even in the same room where other members of the family are sleeping."[52]

GR No. 151858

2003-11-27

PEOPLE v. JOSELITO PASCUA Y TEOPE

YNARES-SANTIAGO, J.

In addition, the trial court should have also ordered appellant to pay the victim P50,000.00 as civil indemnity ex delicto. In People v. Padrigone,[19] citing People v. Belga, [20] we held that civil indemnity is mandatory upon the finding of the fact of rape; it is distinct from and should not be denominated as moral damages which are based on different jural foundations and assessed by the court in the exercise of sound discretion.

GR No. 146956

2003-07-25

PEOPLE v. ROGER FEDERICO Y BUNGGAO

YNARES-SANTIAGO, J.

Also, no woman would concoct a story of defloration, allow an examination of her private parts and subject herself to public trial or ridicule if she has not, in truth, been a victim of rape and impelled to seek justice for the wrong done to her. It is settled jurisprudence that when a woman says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed.[9]

GR Nos. 142993-94

2002-09-05

PEOPLE v. BIANE BONTUAN Y JAGUNOS

YNARES-SANTIAGO, J.

cumulative; and (d) the suppression is an exercise of a privilege.[18] Be that as it may, accused-appellant may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and otherwise consistent with human nature.[19] When a woman declares

GR No. 137664

2002-05-09

PEOPLE v. ROBERTO PADRIGONE

YNARES-SANTIAGO, J.

As regards the matter of damages, the trial court ordered accused-appellant "to indemnify the offended party, Rowena Contridas, the amount of Fifty Thousand Pesos (P50,000.00) as moral damages."[24] In People v. Belga,[25] it was held that civil indemnity is mandatory upon the finding of the fact of rape; it is distinct from and should not be denominated as moral damages which are based on different jural foundations and assessed by the court in the exercise of sound discretion. Thus, consistently with present case law which treats the imposition of civil indemnity as mandatory upon a finding of rape, accused-appellant is ordered to pay the additional amount of fifty thousand (P50,000.00) pesos as civil indemnity ex delicto.[26]

GR Nos. 115236-37

2002-01-29

PEOPLE v. BRYAN FERDINAND DY Y LA MADRID

YNARES-SANTIAGO, J.

In rape cases, courts are guided by the following principles: (1) to accuse a man of rape is easy, but to disprove it is difficult though the accused may be innocent; (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 merit and not be allowed to draw strength from the weakness of the evidence for the defense.[13]

GR Nos. 115236-37

2002-01-29

PEOPLE v. BRYAN FERDINAND DY Y LA MADRID

YNARES-SANTIAGO, J.

Credible witness and credible testimony are the two essential elements for the determination of the weight of a particular testimony. This principle could not ring any truer where the prosecution relies mainly on the testimony of the complainant, corroborated by the medico-legal findings of a physician. Be that as it may, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, convincing and otherwise consistent with human nature.[27]

GR No. 143703

2001-11-29

PEOPLE v. JOSE MUSA Y VILLARAZA

MENDOZA, J.

Indeed, no young girl would falsely accuse her uncle of a heinous crime, willingly undergo an examination of her private parts, and expose herself to a public trial, unless she is motivated by a desire to seek justice for the wrong committed against her.[17] In the case of Vanessa Rochelle, she had no reason to make false charges against accused-appellant. Where no evidence has been shown that the victim had improper motive to falsely implicate the accused in the commission of the crime, the presumption is that no such ill motive exists and her testimony is worthy of full faith and credence.[18]

GR Nos. 129530-31

2001-09-24

PEOPLE v. WILFREDO OLARTE

PER CURIAM

It is not necessary that the victim narrate all the sordid details of the rape. To require her to do so would mean that she must relive the horror and anguish she experienced which, in all probability, she was trying hard to erase from memory. Hence, it would be enough if the victim merely said that she was raped.[24] This Court has held consistently that when a woman declares that she has been raped, she says in effect all that is necessary to mean that she has been raped, and where her testimony passes the test of credibility, the accused may be convicted on the basis thereof.[25]

	GR No. 200508 2013-09-04	PEOPLE v. CHRISTOPHER RIVERA Y ROYO MENDOZA, J.
Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they are lying.[27] [Italicization supplied]
	GR No. 186461 2010-07-05	PEOPLE v. SEVERIANO OGAN VELASCO JR., J.
It bears noting that both the trial and appellate courts did not specify what kind of damages was being awarded apart from civil indemnity.[35] In awarding damages, the trial court should state the factual bases of the award of these damages.[36] Thus, in rape cases, damages may refer to moral and exemplary, and these must be specified as these have different bases.[37]
	GR No. 176742 2008-06-17	PEOPLE v. WENCESLAO ESPINO CHICO-NAZARIO, J.
Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[43] The rule finds an even more stringent application where said findings are sustained by the Court of Appeals.[44]
	GR No. 177749 2007-12-17	PEOPLE v. MANUEL AGUILAR CHICO-NAZARIO, J.
Accordingly, the primordial consideration in a determination concerning the crime of rape is the credibility of complainant's testimony.[35] Time and again, we have held that when it comes to the issue of credibility of the victim or the prosecution witnesses, the findings of the trial courts carry great weight and respect and, generally, the appellate courts will not overturn the said findings unless the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which will alter the assailed decision or affect the result of the case.[36] This is so because trial courts are in the best position to ascertain and measure the sincerity and spontaneity of witnesses through their actual observation of the witnesses' manner of testifying, their demeanor and behavior in court.[37] Trial judges enjoy the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" -- all of which are useful aids for an accurate determination of a witness' honesty and sincerity. Trial judges, therefore, can better determine if such witnesses are telling the truth, being in the ideal position to weigh conflicting testimonies. Again, unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected, for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying.[38] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[39]
	GR No. 176633 2007-09-05	PEOPLE v. ARMANDO SAN ANTONIO CHICO-NAZARIO, J.
Time and again, we have held that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court's observations and conclusions deserve great respect and are often accorded finality, unless there appears in the record some fact or circumstance of weight which the lower court may have overlooked, misunderstood or misappreciated and which, if properly considered, would alter the result of the case. The trial judge enjoys the advantage of observing the witness' deportment and manner of testifying, her "furtive glance, blush of conscious shame, hesitation, flippant or sneering tone, calmness, sigh, or the scant or full realization of an oath" - all of which are useful aids for an accurate determination of a witness' honesty and sincerity. The trial judge, therefore, can better determine if such witnesses were telling the truth, being in the ideal position to weigh conflicting testimonies. Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they are lying.[42] The rule finds an even more stringent application where the said findings are sustained by the Court of Appeals.[43]
	GR No. 171731 2006-08-11	PEOPLE v. JOVEN OCAMPO YNARES-SANTIAGO, J.
In rape cases, courts are guided by the following principles: (1) to accuse a man of rape is easy, but to disprove it is difficult though the accused may be innocent; (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 merit and not be allowed to draw strength from the weakness of the evidence for the defense.[22]
	GR NO. 166040 2006-04-26	NIEL F. LLAVE v. PEOPLE CALLEJO, SR., J.
That petitioner ravished the victim not far from the street where residents passed by does not negate the act of rape committed by petitioner. Rape is not a respecter of time and place. The crime may be committed by the roadside and even in occupied premises.[79] The presence of people nearby does not deter rapists from committing the odious act.[80] In this case, petitioner was so daring that he ravished the private complainant near the house of Teofisto even as commuters passed by, impervious to the fact that a crime was being committed in their midst.
	GR No. 134773 2004-06-29	PEOPLE v. AVELINO MABONGA Y BABON SANDOVAL-GUTIERREZ, J.
Appellant also underscores the impossibility of committing rape in the presence of people, such as his wife and neighbors. But it is a common judicial experience that "the presence of people nearby does not deter rapists from committing their odious act. Rape can be committed even in places where people congregate, in parks, along the roadside, within school premises, inside a house where there are several occupants and even in the same room where other members of the family are sleeping."[52]
	GR No. 151858 2003-11-27	PEOPLE v. JOSELITO PASCUA Y TEOPE YNARES-SANTIAGO, J.
In addition, the trial court should have also ordered appellant to pay the victim P50,000.00 as civil indemnity ex delicto. In People v. Padrigone,[19] citing People v. Belga, [20] we held that civil indemnity is mandatory upon the finding of the fact of rape; it is distinct from and should not be denominated as moral damages which are based on different jural foundations and assessed by the court in the exercise of sound discretion.
	GR No. 146956 2003-07-25	PEOPLE v. ROGER FEDERICO Y BUNGGAO YNARES-SANTIAGO, J.
Also, no woman would concoct a story of defloration, allow an examination of her private parts and subject herself to public trial or ridicule if she has not, in truth, been a victim of rape and impelled to seek justice for the wrong done to her. It is settled jurisprudence that when a woman says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed.[9]
	GR Nos. 142993-94 2002-09-05	PEOPLE v. BIANE BONTUAN Y JAGUNOS YNARES-SANTIAGO, J.
cumulative; and (d) the suppression is an exercise of a privilege.[18] Be that as it may, accused-appellant may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and otherwise consistent with human nature.[19] When a woman declares
	GR No. 137664 2002-05-09	PEOPLE v. ROBERTO PADRIGONE YNARES-SANTIAGO, J.
As regards the matter of damages, the trial court ordered accused-appellant "to indemnify the offended party, Rowena Contridas, the amount of Fifty Thousand Pesos (P50,000.00) as moral damages."[24] In People v. Belga,[25] it was held that civil indemnity is mandatory upon the finding of the fact of rape; it is distinct from and should not be denominated as moral damages which are based on different jural foundations and assessed by the court in the exercise of sound discretion. Thus, consistently with present case law which treats the imposition of civil indemnity as mandatory upon a finding of rape, accused-appellant is ordered to pay the additional amount of fifty thousand (P50,000.00) pesos as civil indemnity ex delicto.[26]
	GR Nos. 115236-37 2002-01-29	PEOPLE v. BRYAN FERDINAND DY Y LA MADRID YNARES-SANTIAGO, J.
In rape cases, courts are guided by the following principles: (1) to accuse a man of rape is easy, but to disprove it is difficult though the accused may be innocent; (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 merit and not be allowed to draw strength from the weakness of the evidence for the defense.[13]
	GR Nos. 115236-37 2002-01-29	PEOPLE v. BRYAN FERDINAND DY Y LA MADRID YNARES-SANTIAGO, J.
Credible witness and credible testimony are the two essential elements for the determination of the weight of a particular testimony. This principle could not ring any truer where the prosecution relies mainly on the testimony of the complainant, corroborated by the medico-legal findings of a physician. Be that as it may, the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, convincing and otherwise consistent with human nature.[27]
	GR No. 143703 2001-11-29	PEOPLE v. JOSE MUSA Y VILLARAZA MENDOZA, J.
Indeed, no young girl would falsely accuse her uncle of a heinous crime, willingly undergo an examination of her private parts, and expose herself to a public trial, unless she is motivated by a desire to seek justice for the wrong committed against her.[17] In the case of Vanessa Rochelle, she had no reason to make false charges against accused-appellant. Where no evidence has been shown that the victim had improper motive to falsely implicate the accused in the commission of the crime, the presumption is that no such ill motive exists and her testimony is worthy of full faith and credence.[18]
	GR Nos. 129530-31 2001-09-24	PEOPLE v. WILFREDO OLARTE PER CURIAM
It is not necessary that the victim narrate all the sordid details of the rape. To require her to do so would mean that she must relive the horror and anguish she experienced which, in all probability, she was trying hard to erase from memory. Hence, it would be enough if the victim merely said that she was raped.[24] This Court has held consistently that when a woman declares that she has been raped, she says in effect all that is necessary to mean that she has been raped, and where her testimony passes the test of credibility, the accused may be convicted on the basis thereof.[25]

PEOPLE v. ANTONIO BELGA