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GR No. 195424

2015-06-15

BERSAMIN, J.

The RTC found sufficient circumstantial evidence to prove the guilt of the accused. Being the trial court, it was in the best and unique position to pass upon and assess the credibility of the witnesses and of their testimonies by virtue of its direct opportunity to observe the witnesses first hand and to note their demeanor, conduct, and attitude under rigorous examination that were significant in evaluating their sincerity as witnesses and determining the credibility of their testimonies. Considering that the RTC's findings were adopted by the CA, the Court is now bound by such findings unless the accused or the record turns up compelling reasons to disregard the findings,[29] like their being unnatural, or improbable, or devoid of evidentiary support. Yet, no such reasons were advanced by him, or turned up on the record.

GR No. 210430

2015-02-18

PEOPLE v. RONALD NICAL Y ALMINARIO

REYES, J.

In People v. Alicante,[16] the Court held that the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and consistent with human nature and the normal course of things.[17] Truly, the absence of lacerated wounds in the complainant's vagina does not negate sexual intercourse.[18] In fact, as used in our Revised Penal Code (RPC), "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not require that the vagina be penetrated or that the hymen be ruptured.[19]

GR No. 211002

2015-01-21

RICHARD RICALDE v. PEOPLE

LEONEN, J.

This court has explained the merely corroborative character of expert testimony and the possibility of convictions for rape based on the victim's credible lone testimony.[88]

GR No. 192232

2014-12-10

PEOPLE v. JOSE ESTALIN PRODENCIADO

DEL CASTILLO, J.

Time and again, the Court has repeatedly held that it is not incumbent upon the victim to establish the date when she was raped for purposes of convicting the perpetrator. This is because "[i]n rape cases, the date of commission is not an essential element of the offense; what is material is its occurrence,"[19] which in this case, was sufficiently established by "AAA."

GR No. 199100

2014-07-18

PEOPLE v. ROSENDO AMARO

PEREZ, J.

On the other hand, appellant set-up the defense of denial and alibi. It is jurisprudential that denial and alibi are intrinsically weak defenses which must be buttressed by strong evidence of non-culpability to merit credibility. Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the child-victim of the identity of the appellant and his involvement in the crime attributed to him.[18] Alibi is evidence negative in nature and self-serving and cannot attain more credibility than the testimonies of prosecution witnesses who testify on clear and positive evidence.[19]

GR No. 207763

2014-06-30

PEOPLE v. ROLANDO RONDINA

REYES, J.

It is true that the absence of lacerated wounds in AAA's vagina does not negate sexual intercourse.[27] Laceration of the hymen, considered the most telling and irrefutable physical evidence of sexual assault, is not always essential to establish the consummation of the crime of rape. In the context used in the RPC, "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not necessarily require that the vagina be penetrated or that the hymen be ruptured.[28] But when the victim says that the accused inserted his penis into her vagina and pushed and pulled inside her "for a long time," and she felt pain and blood oozed from her organ, the stark absence of any vaginal tear or laceration will have to be medically explained, or else, the Court is left with no inference other than that the charge of rape may have been a mere fabrication.

GR No. 202122

2014-01-15

PEOPLE v. BERNABE PAREJA Y CRUZ

LEONARDO-DE CASTRO, J.

This Court has time and again held that an accused can be convicted of rape on the basis of the sole testimony of the victim. In People v. Colorado,[42] we said: [A] medical certificate is not necessary to prove the commission of rape, as even a medical examination of the victim is not indispensable in a prosecution for rape. Expert testimony is merely corroborative in character and not essential to conviction. x x x.

GR No. 190318

2013-11-27

PEOPLE v. ROBERTO VELASCO

LEONARDO-DE CASTRO, J.

With regard to appellant's argument that the findings of the medico-legal report do not support the allegation that the victim was indeed raped, we cannot give any credit to such claim in light of established jurisprudence holding that a medical certificate is not necessary to prove the commission of rape, as even a medical examination of the victim is not indispensable in a prosecution for rape.[21]

GR No. 196051

2013-10-02

PEOPLE v. JADE CUAYCONG Y REMONQUILLO

LEONARDO-DE CASTRO, J.

In addition, we have previously ruled that expert testimony is merely corroborative in character and not essential to conviction since an accused can still be convicted of rape on the basis of the sole testimony of the private complainant.[25] In other words, the medico-legal officer's testimony cannot be considered to possess comparative weight to that of the victim's assertions of rape and, thus, can be disregarded without affecting the finding of guilt imposed upon the accused.

GR No. 200508

2013-09-04

PEOPLE v. CHRISTOPHER RIVERA Y ROYO

MENDOZA, J.

In his last ditch effort to secure his exoneration, Rivera pointed out that the records were bereft of evidence to prove that AAA suffered vaginal lacerations.[38] The lack of lacerated wounds in the vagina, however, does not negate sexual intercourse.[39] Laceration of the hymen, even if considered the most telling and irrefutable physical evidence of sexual assault, is not always essential to establish the consummation of the crime of rape. In the context used in the RPC, "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not necessarily require that the vagina be penetrated or that the hymen be ruptured.[40] Accordingly, granting arguendo that AAA did not suffer any laceration, Rivera would still be guilty of rape after it was clearly established that he did succeed in having carnal knowledge of her. At any rate, it has been repeatedly held that the medical examination of the victim is not indispensable in a prosecution for rape. Expert testimony is merely corroborative in character and not essential to a conviction.[41]

	GR No. 195424 2015-06-15	PEOPLE v. RUDY NUYOK BERSAMIN, J.
The RTC found sufficient circumstantial evidence to prove the guilt of the accused. Being the trial court, it was in the best and unique position to pass upon and assess the credibility of the witnesses and of their testimonies by virtue of its direct opportunity to observe the witnesses first hand and to note their demeanor, conduct, and attitude under rigorous examination that were significant in evaluating their sincerity as witnesses and determining the credibility of their testimonies. Considering that the RTC's findings were adopted by the CA, the Court is now bound by such findings unless the accused or the record turns up compelling reasons to disregard the findings,[29] like their being unnatural, or improbable, or devoid of evidentiary support. Yet, no such reasons were advanced by him, or turned up on the record.
	GR No. 210430 2015-02-18	PEOPLE v. RONALD NICAL Y ALMINARIO REYES, J.
In People v. Alicante,[16] the Court held that the accused may be convicted on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and consistent with human nature and the normal course of things.[17] Truly, the absence of lacerated wounds in the complainant's vagina does not negate sexual intercourse.[18] In fact, as used in our Revised Penal Code (RPC), "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not require that the vagina be penetrated or that the hymen be ruptured.[19]
	GR No. 211002 2015-01-21	RICHARD RICALDE v. PEOPLE LEONEN, J.
This court has explained the merely corroborative character of expert testimony and the possibility of convictions for rape based on the victim's credible lone testimony.[88]
	GR No. 192232 2014-12-10	PEOPLE v. JOSE ESTALIN PRODENCIADO DEL CASTILLO, J.
Time and again, the Court has repeatedly held that it is not incumbent upon the victim to establish the date when she was raped for purposes of convicting the perpetrator. This is because "[i]n rape cases, the date of commission is not an essential element of the offense; what is material is its occurrence,"[19] which in this case, was sufficiently established by "AAA."
	GR No. 199100 2014-07-18	PEOPLE v. ROSENDO AMARO PEREZ, J.
On the other hand, appellant set-up the defense of denial and alibi. It is jurisprudential that denial and alibi are intrinsically weak defenses which must be buttressed by strong evidence of non-culpability to merit credibility. Mere denial, without any strong evidence to support it, can scarcely overcome the positive declaration by the child-victim of the identity of the appellant and his involvement in the crime attributed to him.[18] Alibi is evidence negative in nature and self-serving and cannot attain more credibility than the testimonies of prosecution witnesses who testify on clear and positive evidence.[19]
	GR No. 207763 2014-06-30	PEOPLE v. ROLANDO RONDINA REYES, J.
It is true that the absence of lacerated wounds in AAA's vagina does not negate sexual intercourse.[27] Laceration of the hymen, considered the most telling and irrefutable physical evidence of sexual assault, is not always essential to establish the consummation of the crime of rape. In the context used in the RPC, "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not necessarily require that the vagina be penetrated or that the hymen be ruptured.[28] But when the victim says that the accused inserted his penis into her vagina and pushed and pulled inside her "for a long time," and she felt pain and blood oozed from her organ, the stark absence of any vaginal tear or laceration will have to be medically explained, or else, the Court is left with no inference other than that the charge of rape may have been a mere fabrication.
	GR No. 202122 2014-01-15	PEOPLE v. BERNABE PAREJA Y CRUZ LEONARDO-DE CASTRO, J.
This Court has time and again held that an accused can be convicted of rape on the basis of the sole testimony of the victim. In People v. Colorado,[42] we said: [A] medical certificate is not necessary to prove the commission of rape, as even a medical examination of the victim is not indispensable in a prosecution for rape. Expert testimony is merely corroborative in character and not essential to conviction. x x x.
	GR No. 190318 2013-11-27	PEOPLE v. ROBERTO VELASCO LEONARDO-DE CASTRO, J.
With regard to appellant's argument that the findings of the medico-legal report do not support the allegation that the victim was indeed raped, we cannot give any credit to such claim in light of established jurisprudence holding that a medical certificate is not necessary to prove the commission of rape, as even a medical examination of the victim is not indispensable in a prosecution for rape.[21]
	GR No. 196051 2013-10-02	PEOPLE v. JADE CUAYCONG Y REMONQUILLO LEONARDO-DE CASTRO, J.
In addition, we have previously ruled that expert testimony is merely corroborative in character and not essential to conviction since an accused can still be convicted of rape on the basis of the sole testimony of the private complainant.[25] In other words, the medico-legal officer's testimony cannot be considered to possess comparative weight to that of the victim's assertions of rape and, thus, can be disregarded without affecting the finding of guilt imposed upon the accused.
	GR No. 200508 2013-09-04	PEOPLE v. CHRISTOPHER RIVERA Y ROYO MENDOZA, J.
In his last ditch effort to secure his exoneration, Rivera pointed out that the records were bereft of evidence to prove that AAA suffered vaginal lacerations.[38] The lack of lacerated wounds in the vagina, however, does not negate sexual intercourse.[39] Laceration of the hymen, even if considered the most telling and irrefutable physical evidence of sexual assault, is not always essential to establish the consummation of the crime of rape. In the context used in the RPC, "carnal knowledge," unlike its ordinary connotation of sexual intercourse, does not necessarily require that the vagina be penetrated or that the hymen be ruptured.[40] Accordingly, granting arguendo that AAA did not suffer any laceration, Rivera would still be guilty of rape after it was clearly established that he did succeed in having carnal knowledge of her. At any rate, it has been repeatedly held that the medical examination of the victim is not indispensable in a prosecution for rape. Expert testimony is merely corroborative in character and not essential to a conviction.[41]

PEOPLE v. NEIL B. COLORADO