This case has been cited 2 times or more.
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2001-05-21 |
MENDOZA, J. |
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| In considering this appeal, it is well to recall certain principles which have guided this Court in the review of trial court decisions, to wit: (1) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; (2) in view of the nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution stands or falls on its own merits and cannot be allowed to draw strength from the weakness of the defense.[9] Mere accusation is not enough to convict. By the very nature of the crime, the issue in rape cases turns on the credibility of the complainant as only the participants can testify as to its occurrence.[10] In this case, the choice is between the claim of complainant that she was raped on September 19, 1995 by accused-appellant and that of accused-appellant that he and complainant actually engaged in consensual sexual intercourse on the date in question. | |||||
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2001-04-19 |
MENDOZA, J. |
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| Accused-appellant contends that Sinclaire De Guzman's story is incredible and difficult to believe. He stresses the fact that he has been blind for 20 years and that complainant could have simply pushed him away or easily escaped from his clutches had he really tried to rape her. That she did not means that he did not even attempt to molest her.[20] We agree with accused-appellant. Courts are guided by the following principles in adjudging rape cases: (a) An accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove the same; (b) In view of the intrinsic nature of the crime of rape where only two persons are usually involved, 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.[21] By the very nature of the crime, judgments in rape cases turn on the credibility of the complainant as only the participants can testify as to its occurrence.[22] In several cases,[23] we have held that the lone uncorroborated testimony of the complainant is sufficient to warrant a conviction, provided that such is credible, natural, convincing, and consistent with human nature and the normal course of things. However, we have also held that the testimony of the complainant should not be received with precipitate credulity but with the utmost caution.[24] The test for determining the credibility of complainant's testimony is whether it is in conformity with common knowledge and consistent with the experience of mankind. Whatever is repugnant to these standards becomes incredible and lies outside of judicial cognizance.[25] While we are mindful of the rule that the findings of the trial court regarding the credibility of witnesses are generally accorded great respect, and even finality, on appeal, this does not preclude a re-evaluation of the evidence to determine whether a fact or circumstance has not been overlooked or misinterpreted by the trial court.[26] We have not hesitated to reverse judgments of conviction where there are strong indications pointing to the possibility that the rape charge is false.[27] In this case, several circumstances lead us to doubt complainant's claim that she was raped by accused-appellant. | |||||