This case has been cited 4 times or more.
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2009-10-02 |
BRION, J. |
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| In People v. Coloma,[64] we considered an eight-year delay in reporting the long history of rape by the victim's father as understandable and insufficient to render the complaint of a 13-year old daughter incredible. People v. Santos[65] is likewise a noteworthy case on the present issue as we categorically ruled that a four-year delay in reporting a rape did not necessarily taint a victim's testimony when the reason for the delay was satisfactorily explained. In People v. Dimaano,[66] we held that strong apprehensions brought about by fear, stress, or anxiety can leave the offended party doubtful, distrustful and unsure of the proper steps to take in responding to the sexual assault she suffered. | |||||
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2009-09-10 |
LEONARDO-DE CASTRO, J. |
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| The rape victim's delay or hesitation in reporting the crime does not destroy the truth of the charge nor is it an indication of deceit. It is common for a rape victim to prefer silence for fear of her aggressor and the lack of courage to face the public stigma of having been sexually abused. In People v. Coloma[25] we even considered an 8-year delay in reporting the long history of rape by the victim's father as understandable and not enough to render incredible the complaint of a 13-year-old daughter. Thus, in the absence of other circumstances that show that the charge was a mere concoction and impelled by some ill motive, delay in the filing of the complainant is not sufficient to defeat the charge. Here, the failure of AAA's parents to immediately file this case was sufficiently justified by the complainant's father in the latter's testimony, thus: Q But, did you not say, please correct me if I am wrong, you got angry when your wife told you that something happened to Hazel way back in 1996? A Yes, sir. | |||||
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2008-09-11 |
CHICO-NAZARIO, J. |
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| In this connection, it has been held that delay in making a criminal accusation does not impair the credibility of a witness if such delay is satisfactorily explained, as in the case at bar. In People v. Coloma[68] in which the complainant was only 13 years old when first molested by her father, the Court adverted to the father's moral and physical control over the young complainant in explaining the delay of eight years before the complaint against her father was made. | |||||
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2006-11-29 |
TINGA, J. |
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| Neither does AAA's failure to tell her mother about the incident nor her long delay in reporting the matter to the authorities negate rape. As correctly observed by the OSG, the delay in reporting the rape incident does not weaken the case for the prosecution. It is not uncommon for a young girl to conceal assaults on her virtue, especially when the rapist is living with her.[55] In fact, we have previously ruled in People v. Coloma,[56] that even a delay of 8 years is not a sign of fabrication. | |||||