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PEOPLE v. ARMANDO QUILATAN

This case has been cited 9 times or more.

2008-06-27
CHICO-NAZARIO, J.
Undergoing all of the humiliating and invasive procedures for the case the initial police interrogation, the medical examination, the formal charge, the public trial and the cross-examination proves to be the litmus test for truth, especially when endured by a minor who gives her consistent and unwavering testimony on the details of her ordeal. [26]  Despite the serious anguish she suffered in relating her traumatic experience, private complainant gave her testimony in a categorical, straightforward, spontaneous and candid manner and was considered by the trial court to be worthy of belief. It is a matter of judicial cognizance that the tears that were spontaneously shed by a rape victim during her testimony are an indication of credibility.[27]
2008-06-27
CHICO-NAZARIO, J.
Civil indemnity is mandatory upon the finding of the fact of rape.  If the crime of rape is committed or effectively qualified by any of the circumstances under which death penalty is authorized by law, the indemnity for the victim shall be P75,000.00.[49]  Moral damages may additionally be awarded in the amount of P75,000.00,[50] as well as exemplary damages of P25,000.00.[51]
2004-02-13
CARPIO, J.
The time mentioned by Remilyn, that is 3:00 a.m., is at most an estimate. We must bear in mind that appellant roused Remilyn from sleep when he forced himself on her. Remilyn could not have known the exact time as appellant's act abruptly and rudely awakened her. Remilyn's estimate of the time while not precise tends to strengthen the impression that her testimony is unrehearsed. Moreover, no one expects rape victims to remember with precision every detail of the crime. A mis-estimation of time is too immaterial to discredit the testimony of a witness especially where time is not an essential element or has no substantial bearing on the fact of the commission of the offense.[15] What is decisive in a rape charge is the complainant's positive identification of the accused as the malefactor.[16]
2003-08-26
PER CURIAM
Appellant's desperation to save himself is highlighted by his explanation as to why his wife caused the rape charges to be filed against him. Appellant alleged that his wife was having an extramarital affair. Even if it was not necessary, Vetelina chose to present witnesses to proved that appellant's allegations were untrue. Not a few persons convicted of rape have attributed the charges against them to family feuds, resentment, or revenge. However, such alleged motives have never swayed us from lending full credence to the testimony of a complainant who remained steadfast throughout her direct and cross-examination.[29] It is unnatural for a parent to use her offspring as an instrument of malice, especially if it will subject them to embarrassment and even stigma.[30] No mother in her right mind would expose her daughter to the disgrace and trauma resulting from a prosecution for rape if she was not genuinely motivated by a desire to incarcerate the person responsible for her daughter's defilement.[31]
2003-06-26
CARPIO, J.
Appellant's elaborate explanation, raising the twin defenses of denial and alibi, fail to hold up against Danly's testimony.  Many persons convicted of rape have attributed the charges against them to family feuds, resentment, or revenge.  However, such supposed motives have never swayed the Court from lending full credence to the testimony of a rape victim who remained steadfast throughout her direct and cross-examination.[26] It is unnatural for a parent to use her offspring as a battering ram to extract revenge, especially if it will subject them to disgrace and humiliation.[27] No mother in her right mind would expose her daughter to the stigma and trauma resulting from a prosecution for rape if she did not have a genuine desire to seek justice against the person responsible for her daughter's defilement.[28]
2002-08-05
QUISUMBING, J.
or disregarded arbitrarily certain significant facts and circumstances, his assessment of the credibility of witnesses will not be altered on review.[48] Nothing on record appears to show that the trial court omitted or misinterpreted any important detail that would significantly affect the result of this case. The alleged inconsistency regarding the date when Marilou reported the rape appears to us a minor lapse that should not adversely affect the credibility of prosecution witnesses and the weight of their testimonies. Witnesses, including private complainant, are not expected to remember an occurrence with perfect recollection of minute details. A miscalculation as to the exact time of an occurrence is insufficient to discredit the testimony of a witness, especially where time is not an essential element of the offense. In a rape charge, what is decisive is the positive identification of the accused as the malefactor.[49] This requirement, in our view, was sufficiently met in this case by the direct testimony of the offended party herself. Delay in revealing the commission of rape is not an indication of a fabricated charge.[50] It is not uncommon for a young girl to conceal for some time the assault on her virtue. Her hesitation may be due to her youth, the moral ascendancy of the
2001-10-03
MENDOZA, J.
In contrast to the evidence of the prosecution, accused-appellant's only defense is denial.  A bare denial, if unsupported by clear and convincing evidence, is self-serving and cannot be given greater evidentiary weight than the positive declarations of the complainant.[26]
2001-09-28
PARDO, J.
We note, however, that the trial court ordered the accused to indemnify the victims in the amount of P50,000.00 each, without specifying the kind of damages it represented.  This amount must be designated as civil indemnity awarded to the victim upon finding of the commission of the offense and that the accused-appellant committed it.[29]
2001-07-31
MENDOZA, J.
Accused-appellant also raises the defense of denial and alibi. But the bare denial of accused-appellant cannot overcome the positive declarations of complainant. Denial, when unsubstantiated by clear and convincing evidence, constitutes negative self-serving evidence which deserves no greater evidentiary value than the testimony of a credible witness who testified on affirmative matters.[65]