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GR No. 186467

2011-07-13

MENDOZA, J.

The weakness of the defense of the accused, mere denial and frame-up, cannot justify his conviction. The burden is always on the prosecution to prove his guilt beyond reasonable doubt, and not on him to prove his innocence. The merit of his defense is not the issue here. It is safely entrenched in our jurisprudence that the evidence for the prosecution must stand or fall on its own weight and cannot be allowed to draw strength from the weakness of the defense. [34] A finding of guilt must solely rest on the prosecution's own evidence, not on the weakness or even absence of that for the defense. Courts cannot magnify the weakness of the defense and overlook the prosecution's failure to discharge the onus probandi.

GR No. 183094

2010-09-22

PEOPLE v. REYNALDO BARDE

PEREZ, J.

It bears stressing that Elmer's brother, Nicanor, died, his other brother, Luis, was seriously injured and almost died and his two other siblings were also injured because of the explosion. Elmer had more than enough reason to identify the appellant.[56] Indeed, his relationship to the victims cannot be taken against him and it does not automatically impair his credibility and render his testimony less worthy of credence since that no improper motive can be ascribed to him for testifying.[57] It would be unnatural for a relative who is interested in seeking justice for the victims to testify against an innocent person and allow the guilty one to go unpunished.[58] Rather, his inherent desire to bring to justice those whom he personally knew committed a crime against his close relative makes his identification of the appellant all the more credible.[59]

GR NO. 172323

2007-01-29

PEOPLE v. JUDY SALIDAGA Y QUINTANO

CHICO-NAZARIO, J.

The principle has been dinned into the ears of the bench and the bar that in this jurisdiction, accusation is not synonymous with guilt.[32] The proof against him must survive the test of reason; the strongest suspicion must not be permitted to sway judgment.[33] If the evidence is susceptible of two interpretations, one consistent with the innocence of the accused and the other consistent with his guilt, the accused must be acquitted.[34] The overriding consideration is not whether the court doubts the innocence of the accused but whether it entertains a reasonable doubt as to his guilt.[35] If there exists even one iota of doubt, this Court is "under a long standing injunction to resolve the doubt in favor of herein accused-petitioner."[36] The accused may offer no more than a feeble alibi but we are enjoined to proclaim him innocent in the light of insufficient evidence proving his guilt.

GR NO. 150917

2006-09-27

ARTEMIO YADAO v. PEOPLE

CHICO-NAZARIO, J.

Indeed, the evidence of the defense might not, by itself, suffice to emphatically negate the causal relationship between the actions of petitioner Yadao causing injury to the victim and the cause of his death, but the same must be considered in conjunction with the weakness of the evidence given by the prosecution's witness discussed above. Defense witness Dr. Alambra's Autopsy Report, on top of her testimony that upon opening the skull of the victim, she found nothing out of the ordinary in the brain, tend to reinforce the doubt already engendered by the weakness of the prosecution's evidence about the fundamental correlation of the injury and the cause of death. It was incumbent upon the prosecution to demonstrate petitioner Yadao's culpability beyond a reasonable doubt, independently of whatever the defense has offered to exculpate the latter. Conviction must rest on the strength of the prosecution's evidence, not merely on conjectures or suppositions, and certainly not on the weakness of the accused's defense; otherwise, the phrase "constitutional presumption of innocence" will be reduced to nothing but an innocuous grouping of words; worse, to a conspicuous exercise in futulity. As a rule, findings of fact of trial courts are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances that, if taken into account, would materially affect the result of the case.[43] In this case, prescinding from the above discussion, it is arrantly manifest that the RTC, as well as the Court of Appeals, overlooked material and relevant facts that could affect the outcome of the case. The constitutional presumption of innocence aforementioned requires us to take "a more than casual consideration" of every circumstance or doubt favoring the innocence of the accused as court have the imperative duty to "put prosecution evidence under severe testing."[44]

GR NO. 163181

2005-10-19

BONIFACIO L. CAÑAL v. PEOPLE

CALLEJO, SR., J.

The Court likewise rejects the petitioner's contention that the respondent failed to prove his guilt for the crime charged beyond reasonable doubt. It is axiomatic that in criminal cases, the prosecution has to prove the guilt of the accused beyond reasonable doubt. Indeed, by constitutional fiat, the burden of proof falls on the prosecution. Thus, a finding of guilt must rest on the strength of the prosecution's own evidence, and not on the weakness or absence of evidence for the defense.[19]

GR No. 128387

2004-02-05

PEOPLE v. DOMINADOR SUMALINOG

CARPIO, J.

The kinship of the defense witnesses to accused Noel Galvez is not the deciding factor as to why the trial court gave little weight to their testimonies. Rather, it is the fact that the defense witnesses testified to support an alibi. Appellant correctly asserts that standing by itself mere relationship to a party does not automatically discredit a witness. However, if that witness testifies to support the specific defense of alibi, courts view his testimony with skepticism.[11] This is due to the very nature of alibi that the witness affirms. One can easily fabricate an alibi and ask friends and relatives to corroborate it.[12] When a defense witness is a relative of an accused whose defense is alibi, courts have more reason to view such testimony with skepticism.

GR Nos. 148712-15

2004-01-21

PEOPLE v. DOMINADOR CACHOLA Y SALAZAR

PER CURIAM

It is a basic evidentiary rule in criminal law that the prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.[20] If the prosecution fails to discharge that burden, the accused need not present any evidence.[21] Thus, for utter lack of evidence against the six appellants, their acquittal is in order.

GR No. 146100

2002-11-13

PEOPLE v. JOHNNY LOTERONO

YNARES-SANTIAGO, J.

[40] People v. Gerardo Latupan y Sibal @ Jerry, G.R. Nos. 112453-56, 28 June 2001, citing People v. Piamonte, 303 SCRA 577, 588 [1999] .

GR No. 135542

2002-07-18

PEOPLE v. REYNALDO VIÑALON Y SAN AGUSTIN

QUISUMBING, J.

and unreliable, but also because it can be fabricated easily.[39] Their bare-faced denial cannot prevail over their positive identification as the malefactors by eyewitnesses who had no motive to falsely testify against them.[40] The presence of conspiracy between appellants has also been proved amply. It is easily deducible from Devera's act of poking an ice pick at the driver while Viñalon was divesting the passengers of their valuables. Their acts, collectively and individually executed,

GR No. 128720

2002-01-23

S & SGT. ELMER T. VERGARA v. PEOPLE

QUISUMBING, J.

In the light of private complainant's positive identification of petitioner as the perpetrator of the crime, the latter's defense of bare denial and alibi must necessarily fail, as her positive testimony overrides his negative testimony.[18] Alibi is a weak defense that becomes even weaker in the face of positive identification of the accused.[19] Further, an alibi cannot prevail over the positive identification of the petitioner by a credible witness who has no motive to testify falsely.[20]

GR No. 138303

2001-11-26

PEOPLE v. ELROSWELL MANZANO Y BREBONERA

PARDO, J.

In an attempt to further discredit witness Federico, accused-appellant alleged that it was just an afterthought on the part of the witness to impute criminal liability on him because it took Federico about a year to identify accused-appellant as the perpetrator of the crime. However, the lapse of a considerable length of time before a witness comes forward to reveal the identity of the assailant does not taint his credibility and his testimony, especially when there were valid reasons for such delay.[34] When confronted with a shocking incident, one may immediately report the incident to the proper authorities while another, in fear or avoiding involvement in a criminal investigation, may keep to himself what he had witnessed.[35]

GR Nos. 135068-72

2001-09-20

PEOPLE v. MAXIMO RAMOS Y SAN DIEGO

BELLOSILLO, J.

Normally, findings of the trial court as to the credibility of witnesses are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances which, if taken into account, would materially affect the result of the case.[23] From the foregoing, it is clear that the court below overlooked material and relevant facts that could affect the outcome of the case. The constitutional presumption of innocence requires this Court to take "a more than casual consideration" of every circumstance or doubt favoring the innocence of the accused as courts have the imperative duty to "put prosecution evidence under severe testing."[24]

GR No. 114740

2000-02-15

PEOPLE v. ROGELIO GALAM

QUISUMBING, J.

On the issue of credibility of witnesses, we abide by the well-entrenched rule that the "findings of the trial court as to the credibility of witnesses are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances which, if taken into account, would materially affect the result of the case. Having had the opportunity to personally observe and analyze their demeanor and manner of testifying, the trial judge is in a better position to pass judgment on their credibility."[12] In his Brief, appellant emphasizes the following portions of Medina's testimony which he claims demonstrate the prosecution's failure to sufficiently identify him as the assailant:(1) Medina said in his sworn statement - "Noon po ay nasalubong ko si Giliong (appellant) at may kasamang isa pero hindi ko makilala masyado, kasi madilim. Mayroong bitbit si Giliong na sa aking palagay po ay baril kasi po itinatago po sa bandang kanan ng kanyang katawan, x x x"[13]

	GR No. 186467 2011-07-13	PEOPLE v. JAIME GATLABAYAN Y BATARA MENDOZA, J.
The weakness of the defense of the accused, mere denial and frame-up, cannot justify his conviction. The burden is always on the prosecution to prove his guilt beyond reasonable doubt, and not on him to prove his innocence. The merit of his defense is not the issue here. It is safely entrenched in our jurisprudence that the evidence for the prosecution must stand or fall on its own weight and cannot be allowed to draw strength from the weakness of the defense. [34] A finding of guilt must solely rest on the prosecution's own evidence, not on the weakness or even absence of that for the defense. Courts cannot magnify the weakness of the defense and overlook the prosecution's failure to discharge the onus probandi.
	GR No. 183094 2010-09-22	PEOPLE v. REYNALDO BARDE PEREZ, J.
It bears stressing that Elmer's brother, Nicanor, died, his other brother, Luis, was seriously injured and almost died and his two other siblings were also injured because of the explosion. Elmer had more than enough reason to identify the appellant.[56] Indeed, his relationship to the victims cannot be taken against him and it does not automatically impair his credibility and render his testimony less worthy of credence since that no improper motive can be ascribed to him for testifying.[57] It would be unnatural for a relative who is interested in seeking justice for the victims to testify against an innocent person and allow the guilty one to go unpunished.[58] Rather, his inherent desire to bring to justice those whom he personally knew committed a crime against his close relative makes his identification of the appellant all the more credible.[59]
	GR NO. 172323 2007-01-29	PEOPLE v. JUDY SALIDAGA Y QUINTANO CHICO-NAZARIO, J.
The principle has been dinned into the ears of the bench and the bar that in this jurisdiction, accusation is not synonymous with guilt.[32] The proof against him must survive the test of reason; the strongest suspicion must not be permitted to sway judgment.[33] If the evidence is susceptible of two interpretations, one consistent with the innocence of the accused and the other consistent with his guilt, the accused must be acquitted.[34] The overriding consideration is not whether the court doubts the innocence of the accused but whether it entertains a reasonable doubt as to his guilt.[35] If there exists even one iota of doubt, this Court is "under a long standing injunction to resolve the doubt in favor of herein accused-petitioner."[36] The accused may offer no more than a feeble alibi but we are enjoined to proclaim him innocent in the light of insufficient evidence proving his guilt.
	GR NO. 150917 2006-09-27	ARTEMIO YADAO v. PEOPLE CHICO-NAZARIO, J.
Indeed, the evidence of the defense might not, by itself, suffice to emphatically negate the causal relationship between the actions of petitioner Yadao causing injury to the victim and the cause of his death, but the same must be considered in conjunction with the weakness of the evidence given by the prosecution's witness discussed above. Defense witness Dr. Alambra's Autopsy Report, on top of her testimony that upon opening the skull of the victim, she found nothing out of the ordinary in the brain, tend to reinforce the doubt already engendered by the weakness of the prosecution's evidence about the fundamental correlation of the injury and the cause of death. It was incumbent upon the prosecution to demonstrate petitioner Yadao's culpability beyond a reasonable doubt, independently of whatever the defense has offered to exculpate the latter. Conviction must rest on the strength of the prosecution's evidence, not merely on conjectures or suppositions, and certainly not on the weakness of the accused's defense; otherwise, the phrase "constitutional presumption of innocence" will be reduced to nothing but an innocuous grouping of words; worse, to a conspicuous exercise in futulity. As a rule, findings of fact of trial courts are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances that, if taken into account, would materially affect the result of the case.[43] In this case, prescinding from the above discussion, it is arrantly manifest that the RTC, as well as the Court of Appeals, overlooked material and relevant facts that could affect the outcome of the case. The constitutional presumption of innocence aforementioned requires us to take "a more than casual consideration" of every circumstance or doubt favoring the innocence of the accused as court have the imperative duty to "put prosecution evidence under severe testing."[44]
	GR NO. 163181 2005-10-19	BONIFACIO L. CAÑAL v. PEOPLE CALLEJO, SR., J.
The Court likewise rejects the petitioner's contention that the respondent failed to prove his guilt for the crime charged beyond reasonable doubt. It is axiomatic that in criminal cases, the prosecution has to prove the guilt of the accused beyond reasonable doubt. Indeed, by constitutional fiat, the burden of proof falls on the prosecution. Thus, a finding of guilt must rest on the strength of the prosecution's own evidence, and not on the weakness or absence of evidence for the defense.[19]
	GR No. 128387 2004-02-05	PEOPLE v. DOMINADOR SUMALINOG CARPIO, J.
The kinship of the defense witnesses to accused Noel Galvez is not the deciding factor as to why the trial court gave little weight to their testimonies. Rather, it is the fact that the defense witnesses testified to support an alibi. Appellant correctly asserts that standing by itself mere relationship to a party does not automatically discredit a witness. However, if that witness testifies to support the specific defense of alibi, courts view his testimony with skepticism.[11] This is due to the very nature of alibi that the witness affirms. One can easily fabricate an alibi and ask friends and relatives to corroborate it.[12] When a defense witness is a relative of an accused whose defense is alibi, courts have more reason to view such testimony with skepticism.
	GR Nos. 148712-15 2004-01-21	PEOPLE v. DOMINADOR CACHOLA Y SALAZAR PER CURIAM
It is a basic evidentiary rule in criminal law that the prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.[20] If the prosecution fails to discharge that burden, the accused need not present any evidence.[21] Thus, for utter lack of evidence against the six appellants, their acquittal is in order.
	GR No. 146100 2002-11-13	PEOPLE v. JOHNNY LOTERONO YNARES-SANTIAGO, J.
[40] People v. Gerardo Latupan y Sibal @ Jerry, G.R. Nos. 112453-56, 28 June 2001, citing People v. Piamonte, 303 SCRA 577, 588 [1999] .
	GR No. 135542 2002-07-18	PEOPLE v. REYNALDO VIÑALON Y SAN AGUSTIN QUISUMBING, J.
and unreliable, but also because it can be fabricated easily.[39] Their bare-faced denial cannot prevail over their positive identification as the malefactors by eyewitnesses who had no motive to falsely testify against them.[40] The presence of conspiracy between appellants has also been proved amply. It is easily deducible from Devera's act of poking an ice pick at the driver while Viñalon was divesting the passengers of their valuables. Their acts, collectively and individually executed,
	GR No. 128720 2002-01-23	S & SGT. ELMER T. VERGARA v. PEOPLE QUISUMBING, J.
In the light of private complainant's positive identification of petitioner as the perpetrator of the crime, the latter's defense of bare denial and alibi must necessarily fail, as her positive testimony overrides his negative testimony.[18] Alibi is a weak defense that becomes even weaker in the face of positive identification of the accused.[19] Further, an alibi cannot prevail over the positive identification of the petitioner by a credible witness who has no motive to testify falsely.[20]
	GR No. 138303 2001-11-26	PEOPLE v. ELROSWELL MANZANO Y BREBONERA PARDO, J.
In an attempt to further discredit witness Federico, accused-appellant alleged that it was just an afterthought on the part of the witness to impute criminal liability on him because it took Federico about a year to identify accused-appellant as the perpetrator of the crime. However, the lapse of a considerable length of time before a witness comes forward to reveal the identity of the assailant does not taint his credibility and his testimony, especially when there were valid reasons for such delay.[34] When confronted with a shocking incident, one may immediately report the incident to the proper authorities while another, in fear or avoiding involvement in a criminal investigation, may keep to himself what he had witnessed.[35]
	GR Nos. 135068-72 2001-09-20	PEOPLE v. MAXIMO RAMOS Y SAN DIEGO BELLOSILLO, J.
Normally, findings of the trial court as to the credibility of witnesses are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances which, if taken into account, would materially affect the result of the case.[23] From the foregoing, it is clear that the court below overlooked material and relevant facts that could affect the outcome of the case. The constitutional presumption of innocence requires this Court to take "a more than casual consideration" of every circumstance or doubt favoring the innocence of the accused as courts have the imperative duty to "put prosecution evidence under severe testing."[24]
	GR No. 114740 2000-02-15	PEOPLE v. ROGELIO GALAM QUISUMBING, J.
On the issue of credibility of witnesses, we abide by the well-entrenched rule that the "findings of the trial court as to the credibility of witnesses are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances which, if taken into account, would materially affect the result of the case. Having had the opportunity to personally observe and analyze their demeanor and manner of testifying, the trial judge is in a better position to pass judgment on their credibility."[12] In his Brief, appellant emphasizes the following portions of Medina's testimony which he claims demonstrate the prosecution's failure to sufficiently identify him as the assailant:(1) Medina said in his sworn statement - "Noon po ay nasalubong ko si Giliong (appellant) at may kasamang isa pero hindi ko makilala masyado, kasi madilim. Mayroong bitbit si Giliong na sa aking palagay po ay baril kasi po itinatago po sa bandang kanan ng kanyang katawan, x x x"[13]

PEOPLE v. BUENAVENTURA BATIDOR