This case has been cited 25 times or more.
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2014-04-23 |
MENDOZA, J. |
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| In stark contrast to the convincing narration of facts by AAA and BBB are the bare-faced and shaky defenses of denial and alibi proffered by Barcela. Jurisprudence has decreed that alibi and denial cannot prevail over the positive and categorical testimony of the complainant and her identification of the accused.[20] Alibi is an inherently weak defense, which is viewed with suspicion because it can easily be fabricated.[21] Denial is an intrinsically weak defense which must be buttressed with strong evidence of non-culpability to merit credibility.[22] Here, not a shred of competent proof was adduced by Barcela to corroborate his denial and alibi as they are only supported by his self-serving testimony. Hence, they do not merit any evidentiary value. | |||||
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2013-07-17 |
PEREZ, J. |
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| In the same vein, we are not persuaded by the appellant's defense of denial. Well entrenched is the rule that the defense of denial can easily be overcome by a positive identification that is categorical, consistent and untainted by any ill motive on the part of the eyewitnesses testifying on the matter. Nothing is more settled in criminal law jurisprudence than that denial and alibi cannot prevail over the positive and categorical testimony of the witness.[17] As aptly cited in the case of People of the Phils. v. Carlito Mateo y Patawid,[18] the defense of denial cannot surmount the positive and affirmative testimony offered by the prosecution. It is self-serving deserving no weight in law. Alibi, on the other hand, is viewed with suspicion and received with caution, because it can easily be fabricated.[19] For alibi to prosper, appellant must prove not only that he was at some other place when the crime was committed but that it was physically impossible for him to be at the locus criminis at the time of its commission.[20] | |||||
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2012-09-12 |
DEL CASTILLO, J. |
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| In the appreciation of the evidence for the prosecution and the defense, the settled rule is that the assessment of the credibility of witnesses is left largely to the trial court. And in almost all rape cases, the credibility of the victim's testimony is crucial in view of the intrinsic nature of the crime where only the participants therein can testify to its occurrence. "[The victim's] testimony is most vital and must be received with the utmost caution."[9] Once found credible, the victim's lone testimony is sufficient to sustain a conviction.[10] Absent therefore any substantial reason to justify the reversal of the assessments and conclusions of the trial court especially if such findings have been affirmed by the appellate court, the evaluation of the credibility of witnesses is well-nigh conclusive to this Court. | |||||
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2009-02-27 |
NACHURA, J. |
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| Indeed, denial is an intrinsically weak defense which must be buttressed with strong evidence of non-culpability to merit credibility. Alibi is an inherently weak defense, which is viewed with suspicion and received with caution, because it can easily be fabricated.[23] For alibi to prosper, appellant must prove not only that he was at some other place when the crime was committed but that it was physically impossible for him to be at the locus criminis at the time of its commission.[24] | |||||
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2008-08-06 |
QUISUMBING, J. |
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| Rape is generally unwitnessed and oftentimes, the victim is left to testify for herself.[16] Thus, in resolving rape cases, the victim's credibility becomes the primordial consideration. If a victim's testimony is straightforward, convincing and consistent with human nature and the normal course of things, unflawed by any material or significant inconsistency, it passes the test of credibility and the accused may be convicted solely on the basis thereof.[17] To ensure that justice is meted out, extreme care and caution is required in weighing the conflicting testimonies of the complainant and the accused. | |||||
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2008-07-28 |
QUISUMBING, J. |
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| Nothing is more settled in criminal law jurisprudence than that denial and alibi cannot prevail over the positive and categorical testimony of the witness. Denial is an intrinsically weak defense which must be buttressed with strong evidence of non-culpability to merit credibility. Alibi is an inherently weak defense, which is viewed with suspicion and received with caution because it can easily be fabricated.[20] For alibi to prosper, appellant must prove not only that he was at some other place when the crime was committed but that it was physically impossible for him to be at the locus criminis at the time of its commission.[21] Appellant's own evidence shows that he was in the immediate environs when the incident occurred. For he stated that he was just in his own house, barely three meters away from the house of the victim, Estelita.[22] | |||||
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2008-02-26 |
TINGA, J, |
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| Any review of a rape case begins with the settled reality that accusing a person of this crime can be done with facility. Thus, the testimony of the complainant must always be scrutinized with great caution. It may not be easy for her to prove the commission of rape; yet it is even more difficult for the accused, though innocent, to disprove his guilt. This principle must be viewed in relation to that which holds that the evidence for the prosecution must stand or fall on its own merits; it cannot draw strength from the weakness of the evidence for the defense.[28] When a rape victim's testimony, however, is straightforward, unflawed by any material or significant inconsistency, then it deserves full faith and credit and cannot be discarded. Once found credible, her lone testimony is sufficient to sustain a conviction.[29] | |||||
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2008-02-26 |
TINGA, J, |
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| In scrutinizing such credibility, jurisprudence has established the following doctrinal guidelines: (1) the reviewing court will not disturb the findings of the lower court unless there is a showing that it had overlooked, misunderstood, or misapplied some fact or circumstance of weight and substance that could affect the result of the case; (2) the findings of the trial court pertaining to the credibility of witnesses are entitled to great respect and even finality as it had the opportunity to examine their demeanor when they testified on the witness stand; and (3) a witness who testified in clear, positive and convincing manner and remained consistent on cross-examination is a credible witness.[32] | |||||
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2007-09-11 |
TINGA, J, |
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| In rape cases particularly, the conviction or acquittal of the accused most often depends almost entirely on the credibility of the complainant's testimony. By the very nature of this crime, it is generally unwitnessed and usually the victim is left to testify for herself.[15] Her testimony is most vital and must be received with the utmost caution.[16] When a rape victim's testimony, however, is straightforward and marked with consistency despite grueling examination, it deserves full faith and confidence and cannot be discarded. Once found credible, her lone testimony is sufficient to sustain a conviction.[17] | |||||
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2007-09-07 |
TINGA, J. |
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| It is doctrinal that findings of trial courts on the credibility of witnesses deserve a high degree of respect and will not be disturbed on appeal absent a clear showing that the trial court had overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which could reverse a judgment of conviction.[27] In fact, in some instances, such findings are even accorded finality.[28] This is so because the assignment of value to a witness' testimony is essentially the domain of the trial court, not to mention that it is the trial judge who has the direct opportunity to observe the demeanor of a witness on the stand which opportunity provides him unique facility in determining whether or not to accord credence to the testimony[29] or whether the witness is telling the truth or not.[30] | |||||
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2007-08-17 |
TINGA, J. |
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| In rape cases particularly, the conviction or acquittal of the accused most often depends almost entirely on the credibility of the complainant's testimony. By the very nature of this crime, it is generally unwitnessed and usually the victim is left to testify for herself.[32] Her testimony is most vital and must be received with the utmost caution.[33] When a rape victim's testimony, however, is straightforward and marked with consistency despite grueling examination, it deserves full faith and confidence and cannot be discarded. Once found credible, her lone testimony is sufficient to sustain a conviction.[34] | |||||
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2007-08-17 |
TINGA, J. |
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| In stark contrast with AAA's convincing recital of facts, supported as it was by the testimonies of BBB and CCC, are appellant's uncorroborated and shaky defenses of denial and alibi. Nothing is more settled in criminal law jurisprudence than that alibi and denial cannot prevail over the positive and categorical testimony and identification of the complainant.[42] Alibi is an inherently weak defense, which is viewed with suspicion because it can easily be fabricated.[43] Denial is an intrinsically weak defense which must be buttressed with strong evidence of non- culpability to merit credibility.[44] | |||||
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2007-08-17 |
TINGA, J. |
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| In stark contrast with AAA's convincing recital of facts, supported as it was by the testimonies of BBB and CCC, are appellant's uncorroborated and shaky defenses of denial and alibi. Nothing is more settled in criminal law jurisprudence than that alibi and denial cannot prevail over the positive and categorical testimony and identification of the complainant.[42] Alibi is an inherently weak defense, which is viewed with suspicion because it can easily be fabricated.[43] Denial is an intrinsically weak defense which must be buttressed with strong evidence of non- culpability to merit credibility.[44] | |||||
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2007-07-06 |
TINGA, J. |
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| In rape cases particularly, the conviction or acquittal of the accused, more often than not, depends almost entirely on the credibility of the complainant's testimony. By the very nature of this crime, it is generally unwitnessed and usually the victim is left to testify for herself.[35] Her testimony is most vital and must be received with the utmost caution.[36] However, when a rape victim's testimony is straightforward, unflawed by any material or significant inconsistency, then it deserves full faith and credit and cannot be discarded. Once found credible, her lone testimony is sufficient to sustain a conviction.[37] | |||||
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2004-02-13 |
CARPIO, J. |
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| Appellant's alibi and denial cannot prevail over Remilyn's positive and categorical testimony. Alibi is an inherently weak defense and courts must receive it with caution because one can easily fabricate an alibi.[23] For alibi to prosper, it is not enough that the accused show he was at some other place at the time of the commission of the crime.[24] The accused must prove by clear and convincing evidence that it was impossible for him to be at the scene of the crime at the time of its commission.[25] Appellant failed to do this. Moreover, appellant's escape from detention does not help his cause since escape is evidence of guilt.[26] | |||||
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2002-08-01 |
QUISUMBING, J. |
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| including feeble-mindedness and retardation, in the term "deprived of reason" such that the victim is deemed incapable of consenting intelligently to coitus. Settled is the rule that sexual intercourse with a mentally deficient woman constitutes rape.[31] Although we find that here such mental deficiency is only mild or slight in Ellen Navaja's case, still we see no sufficient merit in appellant's second assigned error. We note, however, that in ruling upon appellant's civil liability, the trial court only awarded indemnity ex delicto of P50,000. Pursuant to prevailing jurisprudence, moral damages may be awarded to rape victims, in addition to civil indemnity.[32] Such | |||||
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2001-10-25 |
PER CURIAM |
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| Peculiar to prosecution of rape, more often than not, there are no third-person witnesses to the crime; the victim is generally left to testify for herself against her violator.[35] Thus we find applicable the doctrine that when a woman says she has been raped, she says in general all that is necessary to show that she has been violated, and the accused may be convicted on the sole basis of her testimony provided that it meets the test of credibility.[36] Not only do we find the victim's testimony here straightforward, candid, and consistent on material points, we likewise find that she had no ill-motive to falsely testify against the accused. Appellant's claim that she charged him with rape only after he castigated her about his missing money is unconvincing. Only a truly disturbed girl would concoct stories of rape which would put her own father on death row and drag herself and the rest of her family to a lifetime of shame.[37] Appellant has not shown that complainant was so disturbed mentally and emotionally. We have no doubt whatsoever that appellant is guilty of rape as charged. | |||||
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2001-04-04 |
PER CURIAM |
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| Further, the immediate flight and tarriance of the Ibaos to La Union until Roche's arrest cannot but demonstrate their guilt and desire to evade prosecution.[21] | |||||
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2001-03-01 |
YNARES-SANTIAGO, J. |
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| Owing to the gravity of the penalty imposed, the Court must once again defer to the following principles in reviewing rape cases: 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.[40] Corollary to these legal yardsticks is the dictum that when a victim of rape says she has been defiled, she says in effect all that is necessary to show that rape has been inflicted on her and so long as her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[41] | |||||
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2001-02-19 |
QUISUMBING, J. |
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| In a prosecution for rape the complainant's credibility is the single most important issue since her testimony alone is sufficient to sustain a verdict of conviction.[25] Her testimony is vital and must be received with the utmost caution.[26] In the present cases, we have carefully examined private complainant's narration of her ordeal. She categorically testified that appellant boxed her on the stomach when she tried to resist,[27] then held her hand and covered her mouth while there was phallic penetration of her private parts.[28] She and the other members of her family were also threatened with harm should she report the matter.[29] These circumstance belie appellant's contention that their sexual relationship was consensual. | |||||
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2001-01-31 |
YNARES-SANTIAGO, J. |
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| When a victim of rape says that she has been defiled, she says in effect all that is necessary to show that rape has been inflicted on her and so long as her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[26] Guided by this dictum, the Court has meticulously scrutinized the testimony of complaining witness Alma S. Elpedes and ultimately reached the conclusion that the offense charged did occur. Alma's testimony on the act of rape perpetrated against her by accused-appellant is clear and could have only been narrated by a victim subjected to such a sexual assault. | |||||
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2001-01-24 |
QUISUMBING, J. |
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| In rape trials the issue, more often than not, is the credibility of the victim. Since the participants are usually the only witnesses in the trial of crimes of this nature, the conviction or acquittal of the accused would virtually depend on the credibility of the complainant's testimony. Hence, the testimony of the offended party should not be received with precipitate credulity.[7] But when a rape victim's testimony is straightforward, unflawed by any material or significant inconsistency, then it deserves full credit. If found credible, the declaration of facts given by the offended party alone would be sufficient to sustain a conviction.[8] | |||||
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2000-12-08 |
YNARES-SANTIAGO, J. |
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| In view of the gravity of the penalties imposed on accused-appellant, the Court must once again defer to the following guiding principles in the review of rape cases: 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.[23] Corollary to the foregoing legal yardsticks is the dictum that when a victim of rape says that she has been defiled, she says in effect all that is necessary to show that rape has been inflicted on her and so long as her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[24] | |||||
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2000-10-05 |
YNARES-SANTIAGO, J. |
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| In reviewing rape cases, the Court is 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 of the defense.[22] Corollary to these legal yardsticks is the dictum that when a victim of rape says she has been defiled, she says in effect all that is necessary to show that rape has been inflicted on her and so long as her testimony meets the test of credibility, the accused may be convicted on the basis thereof.[23] | |||||
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2000-08-25 |
PARDO, J. |
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| sufficient to sustain a conviction.[16] Thus, we find no reason to disagree with the trial court's assessment on the credibility of Sonia's testimony.[17] | |||||