This case has been cited 7 times or more.
|
2012-09-11 |
PEREZ, J. |
||||
| As this Court has oft pronounced, both denial and alibi are inherently weak defenses which cannot prevail over the positive and credible testimonies of the prosecution witnesses that appellants committed the crime.[66] For alibi to prosper, the requirements of time and place must be strictly met. It is not enough to prove that appellants were somewhere else when the crime happened. They must also demonstrate by clear and convincing evidence that it was physically impossible for them to have been at the scene of the crime at the approximate time of its commission.[67] Unless substantiated by clear and convincing proof, such defense is negative, self-serving, and undeserving of any weight in law.[68] A mere denial, like alibi, is inherently a weak defense and constitutes self-serving negative evidence, which cannot be accorded greater evidentiary weight than the declaration of credible witnesses who testify on affirmative matters.[69] | |||||
|
2006-08-07 |
CALLEJO, SR., J. |
||||
| It must be stressed that the appellant's defense of denial and alibi was rejected by the trial court. The appellate court ruled as follows: Contrary to the defense's posturing, the accused-appellant's alibi and denial cannot prevail over the positive identification by the private complainant as regards her rapist (People vs. Remoto, 244 SCRA 506). Moreover, for alibi to qualify as a valid defense, it must first be shown that it was physically impossible for the accused to have been present in the locus criminis at the supposed time of commission of the crime (People vs. Caguioa, Sr., 259 SCRA 403). In this case, the accused-appellant cannot cavil at the fact that the house of Carmen Bolo where the private complainant was staying was only a few minutes walk from the house of the accused-appellant.[40] The appellant's denial of the crime charged constitutes negative self-serving evidence which cannot prevail over the positive testimony of Emily that the appellant had defiled her.[41] Moreover, alibi as a defense is inherently weak because it is easy to concoct and difficult to disprove. The appellant must prove, with clear and convincing evidence at the trial that he was in a place other than the situs of the crime, such that it was physically impossible for him to have committed the same.[42] The requirement of time and place must be strictly followed.[43] | |||||
|
2003-08-05 |
DAVIDE JR., C.J. |
||||
| Finally, as to the award of damages. The lower court committed a reversible error, but not for the reasons claimed by Crisanto. The moral damages that may be awarded to the victim of a rape case is within the trial court's discretion and may be imposed without need of evidence of mental, physical, and psychological trauma.[36] We therefore uphold the award of P50,000. However, civil liability, separate from the award of moral damages, is compulsory in rape cases, and jurisprudence sets its limit for simple rape at P50,000.[37] | |||||
|
2003-04-22 |
PANGANIBAN, J. |
||||
| Finally, we note that the trial court erred in awarding only civil indemnity. In rape cases, moral damages are automatically awarded to the victim without need of proof inasmuch as the mental, physical and psychological trauma she suffered is quite obvious.[34] Accordingly, the victim should be awarded an additional P50,000 for each act of rape committed against her. | |||||
|
2003-01-22 |
YNARES-SANTIAGO, J. |
||||
| The testimonies of victims who are young and of tender age deserve full credence and should not be so easily dismissed as a mere fabrication[25] especially where they have absolutely no motive to testify against the accused,[26] as in this case. | |||||
|
2003-01-22 |
YNARES-SANTIAGO, J. |
||||
| What is more, it is unbelievable that the parents of the three private complainants would expose their daughters to embarrassment, ridicule and stigma just to mollify their feelings and falsely accuse an innocent man for a beastly act of rape. Worthy of note is the admission of accused-appellant himself that Alona Bula is his cousin while Rachel Azares and Jovelyn Alohado were his neighbors at Barangay Tagumpay, Puerto Princesa City. Accused-appellant likewise declared that he was even referred to by the three private complainants as their "Kuya" and he regarded them as his sisters. These declarations of accused-appellant only underscore the fact that the private complainants had no ill-motive to falsely accuse him of rape; rather they were motivated by a desire to punish him as the author of the loathsome acts of rape upon their persons. It is well-settled that testimonies of victims who are young and of tender age deserve full credence and should not be so easily dismissed as a mere fabrication,[30] especially where she has absolutely no motive to testify against the accused.[31] | |||||
|
2002-12-12 |
YNARES-SANTIAGO, J. |
||||
| admit that she was raped and consequently subject herself to an examination of her private parts, undergo the trauma and humiliation of a public trial, and embarrass herself with the need to narrate in detail how she was raped, if she was not raped at all.[16] Equally settled is the principle that when a woman says that she has been raped, she says in effect all that is necessary to show that rape has been inflicted on her.[17] Accused-appellant also contends that the findings of the medical doctor who examined the private complainant do not prove that there was rape. To be sure, a medical examination, standing alone, is not sufficient to prove nor disprove the fact of rape[18] | |||||