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GR No. 200645

2014-08-20

PEREZ, J.

As correctly pointed out in the 19 September 2011 Decision of the CA, the court a quo was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. In addition, there was no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[25]

GR No. 194833

2014-07-02

PEOPLE v. PORFERIO BALINO

PEREZ, J.

Upon perusal of the records of the case, we see no reason to reverse or modify the findings of the RTC on the credibility of AAA's testimony, less so in the present case, in which its findings were affirmed by the CA. It is worthy to mention that the court a quo was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. In addition, there is no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[15]

GR No. 200793

2014-06-04

PEOPLE v. MILAN ROXAS Y AGUILUZ

LEONARDO-DE CASTRO, J.

While the informations in this case alleged that accused-appellant is the uncle of the two victims, they did not state that he is their relative within the third civil degree of consanguinity or affinity. The testimonial evidence that accused-appellant's wife and Luisa de Guzman are sisters is immaterial. The circumstance that accused-appellant is a relative of the victims by consanguinity or affinity within the third civil degree must be alleged in the information. In the case at bar, the allegation that accused-appellant is the uncle of private complainants was not sufficient to satisfy the special qualifying circumstance of relationship. It was necessary to specifically allege that such relationship was within the third civil degree. Hence, accused-appellant can only be convicted of simple rape on two counts, for which the penalty imposed is reclusion perpetua in each case.[25]

GR No. 183202

2014-06-02

ALBERTO ALMOJUELA Y VILLANUEVA v. PEOPLE

BRION, J.

As a final note, the general rule is that factual findings of the trial court, especially when affirmed by the CA, deserve great weight and respect.[33] These factual findings should not be disturbed on appeal, unless these are facts of weight and substance that were overlooked or misinterpreted and that would materially affect the disposition of the case.[34]

GR No. 179059

2012-06-13

FIRST DIVISION VICTOR RONDINA v. PEOPLE

DEL CASTILLO, J.

"In order for the defense of alibi to prosper, two requisites must concur: first, the appellant was at a different place at the time the crime was committed, and second, it was physically impossible for him to be at the crime scene at the time of its commission."[60] In this case, the second requisite is not met. Victor himself testified that the distance between Brgy. Macabug and the place where the rape occurred is just three to four kilometers and that the same can be traversed by land transportation in just a few minutes.[61] Hence, it was not physically impossible for him to be at the crime scene at the time of the commission of the crime. Also, even if Victor's alibi is corroborated by Alex, said defense is still unworthy of belief. Alex admitted that Victor was his employer[62] and that he was testifying for Victor as he relied on him for livelihood.[63] "[I]t has been held that alibi becomes more unworthy of merit where it is established mainly by the accused himself and his or her relatives, friends, and comrades-in-arms and not by credible persons."[64]

GR No. 193664

2011-03-23

PEOPLE v. DOMINGO BANAN Y LUMIDO

VELASCO JR., J.

In the instant case, the records clearly show AAA's candor and spontaneity in testifying on the events that transpired. As We held in People v. Caratay, when a witness' testimony is straightforward, candid, and "unflawed by inconsistencies or contradictions in its material points, the same must be given full faith and credit."[40] More importantly, no woman, especially one who is young and immature, "would concoct a story of defloration, allow an examination of her private parts and thereafter allow herself to be perverted in a public trial if she was not motivated solely by the desire to have the culprit apprehended and punished."[41]

GR No. 180997

2010-11-17

SPS. MARIANO AND EMMA BOLAÑOS v. ROSCEF ZUÑIGA BERNARTE

NACHURA, J.

Indeed, the findings of the trial court, with respect to the operative facts and the credibility of witnesses, especially when affirmed by the appellate court, are accorded the highest degree of deference and respect by this Court, except when: (1) the findings of a trial court are grounded entirely on speculations, surmises, or conjectures; (2) a lower court's inference from its factual findings is manifestly mistaken, absurd, or impossible; (3) there is grave abuse of discretion in the appreciation of facts; (4) the findings of the court go beyond the issues of the case or fail to notice certain relevant facts which, if properly considered, will justify a different conclusion; (5) there is misapprehension of facts; and (6) the findings of fact are conclusions without mention of the specific evidence on which they are based are premised on the absence of evidence, or are contradicted by evidence on record.[24] Notably, none of these exceptions is attendant in this case.

GR No. 185716

2010-09-29

PEOPLE v. MIGUELITO MALANA Y LARDISABAY

PEREZ, J.

Denial and alibi are viewed by this Court with disfavor,[24] considering these are inherently weak defenses,[25] especially in light of private complainant's positive and straightforward declarations identifying accused-appellant[26] as the one who committed the bastardly act against her, as well as her straightforward and convincing testimony detailing the circumstances and events leading to the rape.[27]

GR No. 188352

2010-09-01

PEOPLE v. ROLLY DE GUZMAN

MENDOZA, J.

The crime of rape is usually committed under a cloak of privacy that only parties directly involved therein can attest to what actually transpired. Expectedly, their testimonies present a complete divergence of factual assertions. During trial, the prosecution and defense clash tooth-and-nail, with the aim to destroy the other's version. The credibility of witnesses with their respective testimonies then becomes the core issue to be resolved by the trial court. In doing so, it is behooved to exercise strict scrutiny and keen observation of witnesses, utilizing its position "to detect a guilty blush, a slight hesitation, a fearful glance, and an anguished cry."[16] The recent case of People v. Felipe Ayade,[17] thus elucidates: By the distinctive nature of rape cases, conviction usually rests solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things. Accordingly, the Court has consistently adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme caution; and (3) 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 for the defense.

GR No. 184812

2010-07-06

PEOPLE v. ERMILITO ALEGRE Y LAMOSTE

ABAD, J.

Notably, Alegre did not present any evidence, other than his testimony denying the grave charges against him. But to be believed, his denial needed to be buttressed by strong evidence of non-culpability or by the essential weakness of the complainant's allegations.[22] These do not exist here.

GR No. 187742

2010-04-20

PEOPLE v. CRIZALDO PACHECO Y VILLANUEVA

VELASCO JR., J.

We find no reason to reverse the factual findings of the lower court, especially since the CA affirmed such findings. It was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. There is no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[19]

	GR No. 200645 2014-08-20	PEOPLE v. WENDEL OCDOL Y MENDOVA PEREZ, J.
As correctly pointed out in the 19 September 2011 Decision of the CA, the court a quo was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. In addition, there was no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[25]
	GR No. 194833 2014-07-02	PEOPLE v. PORFERIO BALINO PEREZ, J.
Upon perusal of the records of the case, we see no reason to reverse or modify the findings of the RTC on the credibility of AAA's testimony, less so in the present case, in which its findings were affirmed by the CA. It is worthy to mention that the court a quo was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. In addition, there is no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[15]
	GR No. 200793 2014-06-04	PEOPLE v. MILAN ROXAS Y AGUILUZ LEONARDO-DE CASTRO, J.
While the informations in this case alleged that accused-appellant is the uncle of the two victims, they did not state that he is their relative within the third civil degree of consanguinity or affinity. The testimonial evidence that accused-appellant's wife and Luisa de Guzman are sisters is immaterial. The circumstance that accused-appellant is a relative of the victims by consanguinity or affinity within the third civil degree must be alleged in the information. In the case at bar, the allegation that accused-appellant is the uncle of private complainants was not sufficient to satisfy the special qualifying circumstance of relationship. It was necessary to specifically allege that such relationship was within the third civil degree. Hence, accused-appellant can only be convicted of simple rape on two counts, for which the penalty imposed is reclusion perpetua in each case.[25]
	GR No. 183202 2014-06-02	ALBERTO ALMOJUELA Y VILLANUEVA v. PEOPLE BRION, J.
As a final note, the general rule is that factual findings of the trial court, especially when affirmed by the CA, deserve great weight and respect.[33] These factual findings should not be disturbed on appeal, unless these are facts of weight and substance that were overlooked or misinterpreted and that would materially affect the disposition of the case.[34]
	GR No. 179059 2012-06-13	FIRST DIVISION VICTOR RONDINA v. PEOPLE DEL CASTILLO, J.
"In order for the defense of alibi to prosper, two requisites must concur: first, the appellant was at a different place at the time the crime was committed, and second, it was physically impossible for him to be at the crime scene at the time of its commission."[60] In this case, the second requisite is not met. Victor himself testified that the distance between Brgy. Macabug and the place where the rape occurred is just three to four kilometers and that the same can be traversed by land transportation in just a few minutes.[61] Hence, it was not physically impossible for him to be at the crime scene at the time of the commission of the crime. Also, even if Victor's alibi is corroborated by Alex, said defense is still unworthy of belief. Alex admitted that Victor was his employer[62] and that he was testifying for Victor as he relied on him for livelihood.[63] "[I]t has been held that alibi becomes more unworthy of merit where it is established mainly by the accused himself and his or her relatives, friends, and comrades-in-arms and not by credible persons."[64]
	GR No. 193664 2011-03-23	PEOPLE v. DOMINGO BANAN Y LUMIDO VELASCO JR., J.
In the instant case, the records clearly show AAA's candor and spontaneity in testifying on the events that transpired. As We held in People v. Caratay, when a witness' testimony is straightforward, candid, and "unflawed by inconsistencies or contradictions in its material points, the same must be given full faith and credit."[40] More importantly, no woman, especially one who is young and immature, "would concoct a story of defloration, allow an examination of her private parts and thereafter allow herself to be perverted in a public trial if she was not motivated solely by the desire to have the culprit apprehended and punished."[41]
	GR No. 180997 2010-11-17	SPS. MARIANO AND EMMA BOLAÑOS v. ROSCEF ZUÑIGA BERNARTE NACHURA, J.
Indeed, the findings of the trial court, with respect to the operative facts and the credibility of witnesses, especially when affirmed by the appellate court, are accorded the highest degree of deference and respect by this Court, except when: (1) the findings of a trial court are grounded entirely on speculations, surmises, or conjectures; (2) a lower court's inference from its factual findings is manifestly mistaken, absurd, or impossible; (3) there is grave abuse of discretion in the appreciation of facts; (4) the findings of the court go beyond the issues of the case or fail to notice certain relevant facts which, if properly considered, will justify a different conclusion; (5) there is misapprehension of facts; and (6) the findings of fact are conclusions without mention of the specific evidence on which they are based are premised on the absence of evidence, or are contradicted by evidence on record.[24] Notably, none of these exceptions is attendant in this case.
	GR No. 185716 2010-09-29	PEOPLE v. MIGUELITO MALANA Y LARDISABAY PEREZ, J.
Denial and alibi are viewed by this Court with disfavor,[24] considering these are inherently weak defenses,[25] especially in light of private complainant's positive and straightforward declarations identifying accused-appellant[26] as the one who committed the bastardly act against her, as well as her straightforward and convincing testimony detailing the circumstances and events leading to the rape.[27]
	GR No. 188352 2010-09-01	PEOPLE v. ROLLY DE GUZMAN MENDOZA, J.
The crime of rape is usually committed under a cloak of privacy that only parties directly involved therein can attest to what actually transpired. Expectedly, their testimonies present a complete divergence of factual assertions. During trial, the prosecution and defense clash tooth-and-nail, with the aim to destroy the other's version. The credibility of witnesses with their respective testimonies then becomes the core issue to be resolved by the trial court. In doing so, it is behooved to exercise strict scrutiny and keen observation of witnesses, utilizing its position "to detect a guilty blush, a slight hesitation, a fearful glance, and an anguished cry."[16] The recent case of People v. Felipe Ayade,[17] thus elucidates: By the distinctive nature of rape cases, conviction usually rests solely on the basis of the testimony of the victim, provided that such testimony is credible, natural, convincing, and consistent with human nature and the normal course of things. Accordingly, the Court has consistently adhered to the following guiding principles in the review of similar cases, to wit: (1) an accusation for rape can be made with facility; while the accusation is difficult to prove, it is even more difficult for the accused, though innocent, to disprove; (2) considering that, in the nature of things, only two persons are usually involved in the crime of rape, the testimony of the complainant must be scrutinized with extreme caution; and (3) 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 for the defense.
	GR No. 184812 2010-07-06	PEOPLE v. ERMILITO ALEGRE Y LAMOSTE ABAD, J.
Notably, Alegre did not present any evidence, other than his testimony denying the grave charges against him. But to be believed, his denial needed to be buttressed by strong evidence of non-culpability or by the essential weakness of the complainant's allegations.[22] These do not exist here.
	GR No. 187742 2010-04-20	PEOPLE v. CRIZALDO PACHECO Y VILLANUEVA VELASCO JR., J.
We find no reason to reverse the factual findings of the lower court, especially since the CA affirmed such findings. It was in the best position to weigh the evidence presented during trial and ascertain the credibility of the witnesses who testified. There is no showing that the lower court overlooked, misunderstood, or misapplied facts or circumstances of weight which would have affected the outcome of the case.[19]

PEOPLE v. EDGARDO ESTRADA