Lawyerly

GR No. 196735

2014-05-05

LEONEN, J.

According to Cesar Mangrobang, Jr., member of Sigma Rho, he also looked back when Venturina shouted and saw a group of men with baseball bats and lead pipes. Some of them wore pieces of cloth around their heads.[32] He ran when they attacked, but two (2) men, whose faces were covered with pieces of cloth, blocked his way and hit him with lead pipes.[33] While running and parrying the blows, he recognized them as Gilbert Merle Magpantay and Carlo Jolette Fajardo because their masks fell off.[34] He successfully evaded his attackers and ran to the Main Library.[35] He then decided that he needed to help his fraternity brothers and turned back toward Beach House.[36] There, he saw Venturina lying on the ground.[37] Danilo Feliciano, Jr. was beating Venturina up with a lead pipe while Raymund E. Narag was aiming to hit Venturina.[38] When they saw him, they went toward his direction.[39] They were about to hit him when somebody shouted that policemen were coming. Feliciano and Narag then ran away.[40]

GRNo. 181625

2009-10-02

JEROME FLORES v. PEOPLE

YNARES-SANTIAGO, J.

[17] People v. Mansueto, G.R. No. 135196, July 31, 2000, 336 SCRA 715, 734.

GR NO. 171087

2006-07-12

PEOPLE v. FABIAN SADES Y RODEL

YNARES-SANTIAGO, J.

We find no merit in the argument of appellant that the light coming from the "moron" was insufficient to illuminate the face of the assailant. It is settled that when conditions of visibility are favorable, and the witnesses do not appear to be biased, their assertion as to the identity of the malefactor should normally be accepted. Illumination produced by kerosene lamp or a flashlight is sufficient to allow identification of persons. Wicklamps, flashlights, even moonlight or starlight may, in proper situations be considered sufficient illumination, making the attack on the credibility of witnesses solely on that ground unmeritorious.[10]

GR NO. 147039

2006-01-27

DBP POOL OF ACCREDITED INSURANCE COMPANIES v. RADIO MINDANAO NETWORK

AUSTRIA-MARTINEZ, J.

Res gestae, as an exception to the hearsay rule, refers to those exclamations and statements made by either the participants, victims, or spectators to a crime immediately before, during, or after the commission of the crime, when the circumstances are such that the statements were made as a spontaneous reaction or utterance inspired by the excitement of the occasion and there was no opportunity for the declarant to deliberate and to fabricate a false statement. The rule in res gestae applies when the declarant himself did not testify and provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances.[21]

GR No. 157669

2004-04-14

PEOPLE v. JUAN ALCANTARA

YNARES-SATIAGO, J.

We are reluctant to divert from the trial court's findings on this matter as the matter of assigning values to declarations at the witness stand is most competently carried out by the trial judge who, unlike appellate judges, can weigh such testimony in the light of the witness's behavior and attitude at the trial, and the conclusions of the trial judge command great weight and respect.[22] More importantly, we are not surprised that the trial court did not give much weight to the testimony of Atty. Sunga. It was palpably a self-serving statement, corroborated only by none other than the testimonies of appellant's uncle and appellant himself. We also find no evidence on record which would show any reason why an elderly fruit vendor would perjure herself and scheme to convict an innocent person. Absent evidence to show any reason or motive why a witness should testify falsely, the logical conclusion is that no such improper motive exists and [her] testimony is worthy of full faith and credit.[23]

GR Nos. 142683-84

2003-06-23

PEOPLE v. SERGIO JOROLAN Y FAJARDO

QUISUMBING, J.

(c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. Circumstantial evidence is defined as that which proves a fact or series of facts from which the facts in issue may be established by inference.[43]

GR No. 138266

2003-04-30

PEOPLE v. PEDRO CABRERA

QUISUMBING, J.

Such reliance on the rule on res gestae, however, is misplaced. As already explained by this Court in an earlier case, "the rule on res gestae applies when the declarant himself did not testify provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances."[25] Since Shirley Aguilus herself testified, there is absolutely no need for the application of the rule on res gestae. Besides, an appreciable amount of time had elapsed from the time of the alleged killing and the making of the statements at the police station, which brings the case beyond the application of the res gestae rule.[26]

GR No. 145371

2001-09-28

PEOPLE v. VS.BEN AQUINO

DAVIDE, JR., C.J.

Reliance by BEN and ROMEO on the entry in the police blotter that there was no suspect identified and reported is equally without merit. We have held that entries in the police blotter should not be given due significance or probative value, as they do not constitute conclusive proof of the identities of suspected assailants.[36]

GR No. 103550

2001-07-17

PEOPLE v. C2C ROMERICO PORRAS Y CALICTO

PUNO, J.

We are again confronted with the issue of credibility of witnesses. The Court has always recognized that the trial courts are best equipped to pass upon such issue, having had the opportunity to observe firsthand the demeanor and actuations of the witness while on the witness stand. The matter of assigning values to declarations at the witness stand is most competently carried out by the trial judge and his conclusions are entitled to great weight and respect.[80] We see no reason to depart from such ruling.

GR No. 131637

2001-03-01

PEOPLE v. RODELIO PERALTA Y CALAMAAN

BUENA, J.

Accused-appellants' appeal rests on the determination of the credibility of prosecution witness Milagros. It must be observed that where issues raised involve the credibility of witnesses, the trial court's findings on the credibility of witnesses are entitled to the highest degree of respect and will not be disturbed on appeal absent any clear showing that it overlooked, misunderstood or misapplied some facts, or circumstances of weight or substance, which could have affected the result of the case[8] which does not appear in this case. The contention of appellant that prosecution witness Milagros could not have heard such utterances is inadequate to overturn the established fact that Milagros witnessed the stabbing of her husband by accused-appellant Peralta upon the prodding of accused-appellant Quiambao. Considering the proximity of the location and that Milagros was only an arm's length away from her husband, the trial court cannot be faulted for giving credence to witness' testimony that she saw the crime that was then unfolding. Adding credence to her testimony is the fact that relatives of a victim of a crime have a natural knack for remembering the face of the assailant and they, more than anybody else, would be concerned with obtaining justice for the victim by bringing the malefactor to the face of the law. Indeed, family members who have witnessed the killing of a loved one usually strive to remember the faces of the assailants.[9] As the trial court held:" xxx xxx xxx

GR No. 124572

2000-11-20

PEOPLE v. CIRILO OPOSCULO

PARDO, J.

The trial court erred in admitting Senior Police Officer Abarra's testimony by applying the rule on res gestae. The rule of res gestae applies when the declarant himself did not testify provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances.[17]

	GR No. 196735 2014-05-05	PEOPLE v. DANILO FELICIANO LEONEN, J.
According to Cesar Mangrobang, Jr., member of Sigma Rho, he also looked back when Venturina shouted and saw a group of men with baseball bats and lead pipes. Some of them wore pieces of cloth around their heads.[32] He ran when they attacked, but two (2) men, whose faces were covered with pieces of cloth, blocked his way and hit him with lead pipes.[33] While running and parrying the blows, he recognized them as Gilbert Merle Magpantay and Carlo Jolette Fajardo because their masks fell off.[34] He successfully evaded his attackers and ran to the Main Library.[35] He then decided that he needed to help his fraternity brothers and turned back toward Beach House.[36] There, he saw Venturina lying on the ground.[37] Danilo Feliciano, Jr. was beating Venturina up with a lead pipe while Raymund E. Narag was aiming to hit Venturina.[38] When they saw him, they went toward his direction.[39] They were about to hit him when somebody shouted that policemen were coming. Feliciano and Narag then ran away.[40]
	GRNo. 181625 2009-10-02	JEROME FLORES v. PEOPLE YNARES-SANTIAGO, J.
[17] People v. Mansueto, G.R. No. 135196, July 31, 2000, 336 SCRA 715, 734.
	GR NO. 171087 2006-07-12	PEOPLE v. FABIAN SADES Y RODEL YNARES-SANTIAGO, J.
We find no merit in the argument of appellant that the light coming from the "moron" was insufficient to illuminate the face of the assailant. It is settled that when conditions of visibility are favorable, and the witnesses do not appear to be biased, their assertion as to the identity of the malefactor should normally be accepted. Illumination produced by kerosene lamp or a flashlight is sufficient to allow identification of persons. Wicklamps, flashlights, even moonlight or starlight may, in proper situations be considered sufficient illumination, making the attack on the credibility of witnesses solely on that ground unmeritorious.[10]
	GR NO. 147039 2006-01-27	DBP POOL OF ACCREDITED INSURANCE COMPANIES v. RADIO MINDANAO NETWORK AUSTRIA-MARTINEZ, J.
Res gestae, as an exception to the hearsay rule, refers to those exclamations and statements made by either the participants, victims, or spectators to a crime immediately before, during, or after the commission of the crime, when the circumstances are such that the statements were made as a spontaneous reaction or utterance inspired by the excitement of the occasion and there was no opportunity for the declarant to deliberate and to fabricate a false statement. The rule in res gestae applies when the declarant himself did not testify and provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances.[21]
	GR No. 157669 2004-04-14	PEOPLE v. JUAN ALCANTARA YNARES-SATIAGO, J.
We are reluctant to divert from the trial court's findings on this matter as the matter of assigning values to declarations at the witness stand is most competently carried out by the trial judge who, unlike appellate judges, can weigh such testimony in the light of the witness's behavior and attitude at the trial, and the conclusions of the trial judge command great weight and respect.[22] More importantly, we are not surprised that the trial court did not give much weight to the testimony of Atty. Sunga. It was palpably a self-serving statement, corroborated only by none other than the testimonies of appellant's uncle and appellant himself. We also find no evidence on record which would show any reason why an elderly fruit vendor would perjure herself and scheme to convict an innocent person. Absent evidence to show any reason or motive why a witness should testify falsely, the logical conclusion is that no such improper motive exists and [her] testimony is worthy of full faith and credit.[23]
	GR Nos. 142683-84 2003-06-23	PEOPLE v. SERGIO JOROLAN Y FAJARDO QUISUMBING, J.
(c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. Circumstantial evidence is defined as that which proves a fact or series of facts from which the facts in issue may be established by inference.[43]
	GR No. 138266 2003-04-30	PEOPLE v. PEDRO CABRERA QUISUMBING, J.
Such reliance on the rule on res gestae, however, is misplaced. As already explained by this Court in an earlier case, "the rule on res gestae applies when the declarant himself did not testify provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances."[25] Since Shirley Aguilus herself testified, there is absolutely no need for the application of the rule on res gestae. Besides, an appreciable amount of time had elapsed from the time of the alleged killing and the making of the statements at the police station, which brings the case beyond the application of the res gestae rule.[26]
	GR No. 145371 2001-09-28	PEOPLE v. VS.BEN AQUINO DAVIDE, JR., C.J.
Reliance by BEN and ROMEO on the entry in the police blotter that there was no suspect identified and reported is equally without merit. We have held that entries in the police blotter should not be given due significance or probative value, as they do not constitute conclusive proof of the identities of suspected assailants.[36]
	GR No. 103550 2001-07-17	PEOPLE v. C2C ROMERICO PORRAS Y CALICTO PUNO, J.
We are again confronted with the issue of credibility of witnesses. The Court has always recognized that the trial courts are best equipped to pass upon such issue, having had the opportunity to observe firsthand the demeanor and actuations of the witness while on the witness stand. The matter of assigning values to declarations at the witness stand is most competently carried out by the trial judge and his conclusions are entitled to great weight and respect.[80] We see no reason to depart from such ruling.
	GR No. 131637 2001-03-01	PEOPLE v. RODELIO PERALTA Y CALAMAAN BUENA, J.
Accused-appellants' appeal rests on the determination of the credibility of prosecution witness Milagros. It must be observed that where issues raised involve the credibility of witnesses, the trial court's findings on the credibility of witnesses are entitled to the highest degree of respect and will not be disturbed on appeal absent any clear showing that it overlooked, misunderstood or misapplied some facts, or circumstances of weight or substance, which could have affected the result of the case[8] which does not appear in this case. The contention of appellant that prosecution witness Milagros could not have heard such utterances is inadequate to overturn the established fact that Milagros witnessed the stabbing of her husband by accused-appellant Peralta upon the prodding of accused-appellant Quiambao. Considering the proximity of the location and that Milagros was only an arm's length away from her husband, the trial court cannot be faulted for giving credence to witness' testimony that she saw the crime that was then unfolding. Adding credence to her testimony is the fact that relatives of a victim of a crime have a natural knack for remembering the face of the assailant and they, more than anybody else, would be concerned with obtaining justice for the victim by bringing the malefactor to the face of the law. Indeed, family members who have witnessed the killing of a loved one usually strive to remember the faces of the assailants.[9] As the trial court held:" xxx xxx xxx
	GR No. 124572 2000-11-20	PEOPLE v. CIRILO OPOSCULO PARDO, J.
The trial court erred in admitting Senior Police Officer Abarra's testimony by applying the rule on res gestae. The rule of res gestae applies when the declarant himself did not testify provided that the testimony of the witness who heard the declarant complies with the following requisites: (1) that the principal act, the res gestae, be a startling occurrence; (2) the statements were made before the declarant had the time to contrive or devise a falsehood; and (3) that the statements must concern the occurrence in question and its immediate attending circumstances.[17]

PEOPLE v. OSCAR MANSUETO