Lawyerly

GR No. 168693

2009-06-19

LEONARDO-DE CASTRO, J.

Inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect either 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. Besides, a rape victim cannot be expected to recall vividly all the sordid details of the violation committed against her virtue.[29]

GR NO. 168728

2007-08-02

SAMUEL BARREDO Y GOLANI v. VICENTE VINARAO

CORONA, J.

Petitioner's claim that the Board of Pardons and Parole passed a resolution recommending the commutation of his sentence does not justify the issuance of the writ of habeas corpus. Commutation of sentence is a prerogative of the Chief Executive.[26] Hence, even if petitioner's claim were true, the recommendation of the Bureau of Pardons and Parole was just that, a mere recommendation. Until and unless approved by the President, there is no commutation to speak of.

GR NO. 154078

2005-05-06

EDGARDO D. MILLARES v. PHILIPPINE LONG DISTANCE TELEPHONE CO.

SANDOVAL-GUTIERREZ, J.

Retractions are frowned upon by the courts. A retraction of a testimony is exceedingly unreliable, for there is always the probability that it may later on be repudiated. Courts look with disfavor upon retractions, because they can easily be obtained from witnesses through intimidation or for monetary consideration. A retraction does not necessarily negate an earlier declaration.[5]

GR Nos. 148139-43

2003-10-15

PEOPLE v. HERMENIO CANOY

PER CURIAM

In the case before us, we find no satisfactory factual basis that would move us to doubt the trustworthiness of the complainant's recital as to abandon the findings of the trial court. The supposed inconsistencies in the testimonies of the complainant cited by the appellant refer to minor and peripheral details which do not go into the elements of the crime. It is an oft-repeated rule in criminal cases that minor inconsistencies in the statement of a witness do not affect his credibility.[15] On the contrary, they strengthen rather than weaken the witness' credibility as they erase any suspicion of a rehearsed testimony.[16]

GR No. 148134

2003-07-08

PEOPLE v. GEORGE BUENAFLOR Y LABNOTIN

PUNO, J.

It has been held in a long line of cases that the findings of the trial court on the credibility of witnesses and their testimonies are accorded great respect. It is the trial judge who sees the behavior and demeanor of the witness in court, her apparent possession or lack of intelligence, as well as her understanding of the obligation of an oath. The evaluation or assessment made by the trial court acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony.[13] In the case at bar, no compelling reason exists to disturb the trial court's finding disregarding the testimonies of the defense witnesses and upholding the credibility of Merly who stood firm on her claim and unshakable in her testimony.

GR Nos. 148368-70

2003-07-08

PEOPLE v. EDUARDO FABIAN Y MARI

PUNO, J.

It has been held in a long line of cases that the findings of the trial court on the credibility of witnesses and their testimonies are accorded great respect. It is the trial judge who sees the behavior and demeanor of the witness in court. The evaluation or assessment made by the trial court acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony.[16] In the case at bar, no compelling reason exists to disturb the trial court's finding disregarding the testimonies of the defense witnesses and upholding the credibility of Marietta who stood firm on her claim and testimony all throughout the trial. Her very clear and straightforward testimony can stand alone to warrant a conviction, particularly so that no proof of ill-motive on the part of Marietta was clearly shown to exist in filing these cases against the appellant. The defense failed poorly in proving that Marietta was motivated to falsely implicate the appellant in the commission of such a grave crime. The absence of convincing evidence showing any such improper motive on the part of Marietta strongly supports the conclusion that no such improper motive exists, and that her testimony is worthy of full faith and credence.[17] It is settled that a person accused of rape can be convicted solely on the testimony of the victim if the trial court finds said testimony to be credible, natural, convincing, and consistent with human nature and the normal course of things.

GR Nos. 140961-63

2003-01-14

PEOPLE v. BOBBY GALIGAO

YNARES-SANTIAGO, J.

Established is the rule that testimonies of rape victims, especially child victims, are given full weight and credit.[15] In the case at bar, the victims were barely eight, ten and thirteen years old when they were raped. In a litany of cases, we have ruled that when a woman, more so if she is a minor, says she has been raped, she says, in effect, all that is necessary to prove that rape was committed.[16] Youth and immaturity are generally badges of truth.[17] Courts usually give greater weight to the testimony of a girl who is a victim of sexual assault, especially a minor, particularly in cases of incestuous rape, because no woman would be willing to undergo a public trial and put up with the shame, humiliation and dishonor of exposing her own degradation were it not to condemn an injustice and to have the offender apprehended and punished.[18]

GR No. 144082-83

2002-04-18

PEOPLE v. FAUSTINO DULAY

YNARES-SANTIAGO, J.

The Court sees no reason to depart from the conclusions of the trial court whose findings of facts are accorded great respect, being in the unique position to observe the demeanor, act, conduct, and attitude of the witnesses in court while testifying.[14] Verily, the trial court correctly disregarded the ill motive imputed by accused-appellant on the relatives of the complainant. It is highly improbable that they would concoct a story of defloration, allow an examination of complainant's private parts and submit her to public humiliation and scrutiny via an open trial, if her sordid tale was not true and their sole motivation was not to have the culprit apprehended and punished.[15]

GR Nos. 140333-34

2001-12-11

PEOPLE v. LOVE JOY DE GUZMAN

PER CURIAM

Well settled is the rule that no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via a public trial if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished.[22] A young girl's revelation that she has been raped coupled with her voluntary submission to medical examination and her willingness to undergo pubic trial where she would be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction.[23] Courts usually give credence to the testimony of a girl who is a victim of sexual assault particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice. Needless to say, it is settled jurisprudence that testimonies of child victims are given full weight and credit, since 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. Youth and immaturity are generally badges of truth and sincerity.[24]

GR Nos. 136317-18

2001-11-22

PEOPLE v. EDUARDO YAOTO

YNARES-SANTIAGO, J.

Besides, no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via an open trial, if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished. A young girl's revelation that she was raped, coupled with her voluntary submission to medical examination and her willingness to undergo public trial where she could be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction. Courts usually give credence to the testimony of a girl who is a victim of sexual assault, particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice.[11]

GR Nos. 136867-68

2001-09-24

PEOPLE v. RODRIGO GALVEZ Y JEREZ

YNARES-SANTIAGO, J.

Well settled is the rule that no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via a public trial if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished.[32] A young girl's revelation that she has been raped coupled with her voluntary submission to medical examination and her willingness to undergo pubic trial where she would be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction.[33] Courts usually give credence to the testimony of a girl who is a victim of sexual assault particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice. Needless to say, it is settled jurisprudence that testimonies of child victims are given full weight and credit, since 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. Youth and immaturity are generally badges of truth and sincerity.[34]

GR No. 132714

2001-09-06

PEOPLE v. RENATO LALINGJAMAN

YNARES-SANTIAGO, J.

Established is the rule that testimonies of rape victims, especially child victims, are given full weight and credit.[17] It bears emphasis that the victim was barely thirteen when she was raped. In a litany of cases, this Court has applied the well-settled rule that when a woman, more so if she is a minor, says she has been raped, she says, in effect, all that is necessary to prove that rape was committed.[18] Youth and immaturity are generally badges of truth.[19] Courts usually give greater weight to the testimony of a girl who is a victim of sexual assault, especially a minor, particularly in cases of incestuous rape, because no woman would be willing to undergo a public trial and put up with the shame, humiliation and dishonor of exposing her own degradation were it not to condemn an injustice and to have the offender apprehended and punished.[20]

	GR No. 168693 2009-06-19	PEOPLE v. JESSIE MARIANO LEONARDO-DE CASTRO, J.
Inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect either 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. Besides, a rape victim cannot be expected to recall vividly all the sordid details of the violation committed against her virtue.[29]
	GR NO. 168728 2007-08-02	SAMUEL BARREDO Y GOLANI v. VICENTE VINARAO CORONA, J.
Petitioner's claim that the Board of Pardons and Parole passed a resolution recommending the commutation of his sentence does not justify the issuance of the writ of habeas corpus. Commutation of sentence is a prerogative of the Chief Executive.[26] Hence, even if petitioner's claim were true, the recommendation of the Bureau of Pardons and Parole was just that, a mere recommendation. Until and unless approved by the President, there is no commutation to speak of.
	GR NO. 154078 2005-05-06	EDGARDO D. MILLARES v. PHILIPPINE LONG DISTANCE TELEPHONE CO. SANDOVAL-GUTIERREZ, J.
Retractions are frowned upon by the courts. A retraction of a testimony is exceedingly unreliable, for there is always the probability that it may later on be repudiated. Courts look with disfavor upon retractions, because they can easily be obtained from witnesses through intimidation or for monetary consideration. A retraction does not necessarily negate an earlier declaration.[5]
	GR Nos. 148139-43 2003-10-15	PEOPLE v. HERMENIO CANOY PER CURIAM
In the case before us, we find no satisfactory factual basis that would move us to doubt the trustworthiness of the complainant's recital as to abandon the findings of the trial court. The supposed inconsistencies in the testimonies of the complainant cited by the appellant refer to minor and peripheral details which do not go into the elements of the crime. It is an oft-repeated rule in criminal cases that minor inconsistencies in the statement of a witness do not affect his credibility.[15] On the contrary, they strengthen rather than weaken the witness' credibility as they erase any suspicion of a rehearsed testimony.[16]
	GR No. 148134 2003-07-08	PEOPLE v. GEORGE BUENAFLOR Y LABNOTIN PUNO, J.
It has been held in a long line of cases that the findings of the trial court on the credibility of witnesses and their testimonies are accorded great respect. It is the trial judge who sees the behavior and demeanor of the witness in court, her apparent possession or lack of intelligence, as well as her understanding of the obligation of an oath. The evaluation or assessment made by the trial court acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony.[13] In the case at bar, no compelling reason exists to disturb the trial court's finding disregarding the testimonies of the defense witnesses and upholding the credibility of Merly who stood firm on her claim and unshakable in her testimony.
	GR Nos. 148368-70 2003-07-08	PEOPLE v. EDUARDO FABIAN Y MARI PUNO, J.
It has been held in a long line of cases that the findings of the trial court on the credibility of witnesses and their testimonies are accorded great respect. It is the trial judge who sees the behavior and demeanor of the witness in court. The evaluation or assessment made by the trial court acquires greater significance in rape cases because from the nature of the offense, the only evidence that can oftentimes be offered to establish the guilt of the accused is the victim's testimony.[16] In the case at bar, no compelling reason exists to disturb the trial court's finding disregarding the testimonies of the defense witnesses and upholding the credibility of Marietta who stood firm on her claim and testimony all throughout the trial. Her very clear and straightforward testimony can stand alone to warrant a conviction, particularly so that no proof of ill-motive on the part of Marietta was clearly shown to exist in filing these cases against the appellant. The defense failed poorly in proving that Marietta was motivated to falsely implicate the appellant in the commission of such a grave crime. The absence of convincing evidence showing any such improper motive on the part of Marietta strongly supports the conclusion that no such improper motive exists, and that her testimony is worthy of full faith and credence.[17] It is settled that a person accused of rape can be convicted solely on the testimony of the victim if the trial court finds said testimony to be credible, natural, convincing, and consistent with human nature and the normal course of things.
	GR Nos. 140961-63 2003-01-14	PEOPLE v. BOBBY GALIGAO YNARES-SANTIAGO, J.
Established is the rule that testimonies of rape victims, especially child victims, are given full weight and credit.[15] In the case at bar, the victims were barely eight, ten and thirteen years old when they were raped. In a litany of cases, we have ruled that when a woman, more so if she is a minor, says she has been raped, she says, in effect, all that is necessary to prove that rape was committed.[16] Youth and immaturity are generally badges of truth.[17] Courts usually give greater weight to the testimony of a girl who is a victim of sexual assault, especially a minor, particularly in cases of incestuous rape, because no woman would be willing to undergo a public trial and put up with the shame, humiliation and dishonor of exposing her own degradation were it not to condemn an injustice and to have the offender apprehended and punished.[18]
	GR No. 144082-83 2002-04-18	PEOPLE v. FAUSTINO DULAY YNARES-SANTIAGO, J.
The Court sees no reason to depart from the conclusions of the trial court whose findings of facts are accorded great respect, being in the unique position to observe the demeanor, act, conduct, and attitude of the witnesses in court while testifying.[14] Verily, the trial court correctly disregarded the ill motive imputed by accused-appellant on the relatives of the complainant. It is highly improbable that they would concoct a story of defloration, allow an examination of complainant's private parts and submit her to public humiliation and scrutiny via an open trial, if her sordid tale was not true and their sole motivation was not to have the culprit apprehended and punished.[15]
	GR Nos. 140333-34 2001-12-11	PEOPLE v. LOVE JOY DE GUZMAN PER CURIAM
Well settled is the rule that no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via a public trial if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished.[22] A young girl's revelation that she has been raped coupled with her voluntary submission to medical examination and her willingness to undergo pubic trial where she would be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction.[23] Courts usually give credence to the testimony of a girl who is a victim of sexual assault particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice. Needless to say, it is settled jurisprudence that testimonies of child victims are given full weight and credit, since 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. Youth and immaturity are generally badges of truth and sincerity.[24]
	GR Nos. 136317-18 2001-11-22	PEOPLE v. EDUARDO YAOTO YNARES-SANTIAGO, J.
Besides, no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via an open trial, if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished. A young girl's revelation that she was raped, coupled with her voluntary submission to medical examination and her willingness to undergo public trial where she could be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction. Courts usually give credence to the testimony of a girl who is a victim of sexual assault, particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice.[11]
	GR Nos. 136867-68 2001-09-24	PEOPLE v. RODRIGO GALVEZ Y JEREZ YNARES-SANTIAGO, J.
Well settled is the rule that no woman would concoct a story of defloration, allow an examination of her private parts and submit herself to public humiliation and scrutiny via a public trial if her sordid tale was not true and her sole motivation was not to have the culprit apprehended and punished.[32] A young girl's revelation that she has been raped coupled with her voluntary submission to medical examination and her willingness to undergo pubic trial where she would be compelled to give out the details of an assault on her dignity by, as in this case, her own father, cannot be so easily dismissed as a mere concoction.[33] Courts usually give credence to the testimony of a girl who is a victim of sexual assault particularly if it constitutes incestuous rape because, normally, no person would be willing to undergo the humiliation of a public trial and to testify on the details of her ordeal were it not to condemn an injustice. Needless to say, it is settled jurisprudence that testimonies of child victims are given full weight and credit, since 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. Youth and immaturity are generally badges of truth and sincerity.[34]
	GR No. 132714 2001-09-06	PEOPLE v. RENATO LALINGJAMAN YNARES-SANTIAGO, J.
Established is the rule that testimonies of rape victims, especially child victims, are given full weight and credit.[17] It bears emphasis that the victim was barely thirteen when she was raped. In a litany of cases, this Court has applied the well-settled rule that when a woman, more so if she is a minor, says she has been raped, she says, in effect, all that is necessary to prove that rape was committed.[18] Youth and immaturity are generally badges of truth.[19] Courts usually give greater weight to the testimony of a girl who is a victim of sexual assault, especially a minor, particularly in cases of incestuous rape, because no woman would be willing to undergo a public trial and put up with the shame, humiliation and dishonor of exposing her own degradation were it not to condemn an injustice and to have the offender apprehended and punished.[20]

PEOPLE v. ALFREDO NARDO Y ROSALES