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GR No. 199402

2014-11-12

LEONEN, J.

Hence, "[t]he evaluation of the witnesses' credibility is a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings,"[57] more so when the Court of Appeals affirmed such findings.[58]

GR No. 199402

2014-11-12

PEOPLE v. ENRIQUE QUINTOS Y BADILLA

LEONEN, J.

The exception is when the trial court and/or the Court of Appeals "overlooked or misconstrued substantial facts that could have affected the outcome of the case."[59] No such facts were overlooked or misconstrued in this case.

GR No. 208760

2014-04-23

PEOPLE v. FLORO BUBAN BARCELA

MENDOZA, J.

The circumstance of relationship, Barcela being the common-law husband of BBB's mother, cannot be considered as an ordinary aggravating circumstance to increase the imposable penalty. While it is true that the alternative circumstance of relationship is always aggravating in crimes against chastity[32] (such as Acts of Lasciviousness), regardless of whether the offender is a relative of a higher or lower degree of the offended party, it is only taken into consideration under Article 15 of the Revised Penal Code "when the offended party is the spouse, ascendant, descendant, legitimate, natural or adopted brother or sister, or relative by affinity in the same degree of the offender." The relationship between Barcela and BBB is not covered by any of the relationships mentioned.

GR No. 194236

2013-01-30

PEOPLE v. PATRICIO RAYON

BRION, J.

In People v. Montinola,[26] "the Court held that a child is deemed subjected to other sexual abuse when the child indulges in lascivious conduct under the coercion or influence of an adult."

GR No. 177137

2012-08-23

PEOPLE v. PEDRO BANIG

DEL CASTILLO, J.

A judgment of acquittal is final and is no longer reviewable.[24] As we have previously held in People v. Court of Appeals,[25] "[a] verdict of acquittal is immediately final and a reexamination of the merits of such acquittal, even in the appellate courts, will put the accused in jeopardy for the same offense."[26] True, the finality of acquittal rule is not one without exception as when the trial court commits grave abuse of discretion amounting to lack or excess of jurisdiction. In such a case, the judgment of acquittal may be questioned through the extraordinary writ of certiorari under Rule 65 of the Rules of Court. In the instant case, however, we cannot treat the appeal as a Rule 65 petition as it raises no jurisdictional error that can invalidate the judgment of acquittal. Suffice it to state that the trial court is in the best position to determine the sufficiency of evidence against both appellant and Ginumtad. It is a well-settled rule that this Court accords great respect and full weight to the trial court's findings, unless the trial court overlooked substantial facts which could have affected the outcome of the case.[27] It is not at all irregular for a court to convict one of the accused and acquit the other. The acquittal of Ginumtad in this case is final and it shall not be disturbed.

GR No. 188897

2011-06-06

PEOPLE v. IRENO BONAAGUA Y BERCE

PERALTA, J.

Thus, the appropriate imposable penalty should be that provided in Section 5 (b), Article III of R.A. No. 7610, which is reclusion temporal in its medium period which is fourteen (14) years, eight (8) months and one (1) day to seventeen (17) years and four (4) months. As the crime was committed by the father of the offended party, the alternative circumstance of relationship should be appreciated. In crimes against chastity, such as Acts of Lasciviousness, relationship is always aggravating. [53] Therefore, Ireno should be meted the indeterminate penalty of thirteen (13) years, nine (9) months and eleven (11) days of reclusion temporal, as minimum, to sixteen (16) years, five (5) months and ten (10) days of reclusion temporal, as maximum.

GR No. 182521

2011-02-09

PEOPLE v. ERNESTO FRAGANTE Y AYUDA

CARPIO, J.

The Court is not impressed with appellant's claim that AAA's failure to immediately report the incidents to the proper authorities affected her credibility.[19] Delay could be attributed to the victim's tender age and the appellant's threats.[20] A rape victim's actions are oftentimes influenced by fear, rather than reason.[21] In incestuous rape, this fear is magnified because the victim usually lives under the same roof as the perpetrator or is at any rate subject to his dominance because of their blood relationship.[22]

GR No. 189818

2010-08-09

PEOPLE v. MICHAEL LINDO Y VERGARA

VELASCO JR., J.

That the act was carried out in a public place does not make it unbelievable. The evil in man has no conscience--the beast in him bears no respect for time and place, driving him to commit rape anywhere, even in places where people congregate such as in parks, along the roadside, within school premises, and inside a house where there are other occupants.[6] There is no rule that rape can only be committed in seclusion.[7] The commission of rape is not hindered by time or place as in fact it can be committed even in the most public of places.[8] Clearly, the argument of accused-appellant that there could be no rape as the place was in full view of the public does not have a legal leg to stand on. The fact that the area was in the public eye would not prevent a potential rapist from carrying out his criminal intent.

GR No. 183577

2010-02-01

PEOPLE v. HILARIO ESCOTON

DEL CASTILLO, J.

In this case, minor inconsistencies are expected because (1) "AAA" was a child witness, (2) she was made to testify on a painful and humiliating incident, (3) she was sexually assaulted several times, and (4) she was made to recount details and events that happened two years before she testified.[30]

GR No. 183619

2009-10-13

PEOPLE v. SALVINO SUMINGWA

NACHURA, J.

As the crime was committed by the father of the offended party, the alternative circumstance of relationship should be appreciated. In crimes against chastity, such as Acts of Lasciviousness, relationship is always aggravating.[51]

GR No. 182454

2009-07-23

PEOPLE v. FELIX WASIT

VELASCO JR., J.

We, thus, affirm the trial court's assessment of the testimonial evidence. First, the evaluation of the witnesses' credibility is, to repeat, a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings, unless it overlooked or misconstrued some facts of substance which could have affected the outcome of the case.[18] This rule finds an even more stringent application where the appellate court sustains the trial court's factual determination,[19] as here.

GR No. 173052

2008-12-16

PEOPLE v. ROGELIO PELAGIO Y BERMUDO

AUSTRIA-MARTINEZ, J.

The fact that it took a long time for AAA to report her father's transgressions does not mitigate her credibility. In the first place, appellant threatened to kill AAA and her mother.[19] Moreover, telling people that one has been raped by her own father is not easy to do, and a girl of AAA's age cannot be expected to know how to go about reporting crimes to the proper authorities.[20] Thus, the Court has constantly ruled that:x x x [D]elay in making a criminal accusation [does not] impair the credibility of a witness if such delay is satisfactorily explained. In People v. Coloma, x x x 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. In this case, [complainant] must have been overwhelmed by fear and confusion, and shocked that her own father had defiled her. x x x She also testified that she was afraid to tell her mother because the latter might be angered x x x. Indeed, a survey conducted by the University of the Philippines Center for Women's Studies showed that victims of rape committed by their fathers took much longer in reporting the incidents to the authorities than did other victims. Many factors account for this difference: the fact that the father lives with the victim and constantly exerts moral authority over her, the threat he might make against her, the victim's fear of her mother and other relatives.[21]

GR No. 177354

2008-11-14

PEOPLE v. RICARDO TALAN Y DOE

CARPIO, J.

An appeal in a criminal case opens the entire case for review. The Court can correct errors unassigned in the appeal.[7]

GR No. 183696

2008-10-24

PEOPLE v. NELSON ARRAZ

CARPIO, J.

While appellant admits kissing AAA on the lips around the time of the commission of the rape, appellant denies raping AAA. Appellant's flimsy denial cannot prevail over AAA's positive identification of appellant as the perpetrator of the crime. Moreover, appellant gravely failed to show material facts which the trial court overlooked or misunderstood and which could alter appellant's conviction. Well-settled is the rule that the Court accords great respect and full weight to the trial court's findings, unless the trial court overlooked substantial facts which could have affected the outcome of the case.[13] Appellant's claims involve minor or trifling matters that do not warrant a reversal of the decision of the lower courts.

GR No. 176637

2008-10-06

PEOPLE v. REYNALDO DELA TORRE

CARPIO, J.

An appeal in a criminal case opens the entire case for review. The Court can correct errors unassigned in the appeal.[7]

	GR No. 199402 2014-11-12	PEOPLE v. ENRIQUE QUINTOS Y BADILLA LEONEN, J.
Hence, "[t]he evaluation of the witnesses' credibility is a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings,"[57] more so when the Court of Appeals affirmed such findings.[58]
	GR No. 199402 2014-11-12	PEOPLE v. ENRIQUE QUINTOS Y BADILLA LEONEN, J.
The exception is when the trial court and/or the Court of Appeals "overlooked or misconstrued substantial facts that could have affected the outcome of the case."[59] No such facts were overlooked or misconstrued in this case.
	GR No. 208760 2014-04-23	PEOPLE v. FLORO BUBAN BARCELA MENDOZA, J.
The circumstance of relationship, Barcela being the common-law husband of BBB's mother, cannot be considered as an ordinary aggravating circumstance to increase the imposable penalty. While it is true that the alternative circumstance of relationship is always aggravating in crimes against chastity[32] (such as Acts of Lasciviousness), regardless of whether the offender is a relative of a higher or lower degree of the offended party, it is only taken into consideration under Article 15 of the Revised Penal Code "when the offended party is the spouse, ascendant, descendant, legitimate, natural or adopted brother or sister, or relative by affinity in the same degree of the offender." The relationship between Barcela and BBB is not covered by any of the relationships mentioned.
	GR No. 194236 2013-01-30	PEOPLE v. PATRICIO RAYON BRION, J.
In People v. Montinola,[26] "the Court held that a child is deemed subjected to other sexual abuse when the child indulges in lascivious conduct under the coercion or influence of an adult."
	GR No. 177137 2012-08-23	PEOPLE v. PEDRO BANIG DEL CASTILLO, J.
A judgment of acquittal is final and is no longer reviewable.[24] As we have previously held in People v. Court of Appeals,[25] "[a] verdict of acquittal is immediately final and a reexamination of the merits of such acquittal, even in the appellate courts, will put the accused in jeopardy for the same offense."[26] True, the finality of acquittal rule is not one without exception as when the trial court commits grave abuse of discretion amounting to lack or excess of jurisdiction. In such a case, the judgment of acquittal may be questioned through the extraordinary writ of certiorari under Rule 65 of the Rules of Court. In the instant case, however, we cannot treat the appeal as a Rule 65 petition as it raises no jurisdictional error that can invalidate the judgment of acquittal. Suffice it to state that the trial court is in the best position to determine the sufficiency of evidence against both appellant and Ginumtad. It is a well-settled rule that this Court accords great respect and full weight to the trial court's findings, unless the trial court overlooked substantial facts which could have affected the outcome of the case.[27] It is not at all irregular for a court to convict one of the accused and acquit the other. The acquittal of Ginumtad in this case is final and it shall not be disturbed.
	GR No. 188897 2011-06-06	PEOPLE v. IRENO BONAAGUA Y BERCE PERALTA, J.
Thus, the appropriate imposable penalty should be that provided in Section 5 (b), Article III of R.A. No. 7610, which is reclusion temporal in its medium period which is fourteen (14) years, eight (8) months and one (1) day to seventeen (17) years and four (4) months. As the crime was committed by the father of the offended party, the alternative circumstance of relationship should be appreciated. In crimes against chastity, such as Acts of Lasciviousness, relationship is always aggravating. [53] Therefore, Ireno should be meted the indeterminate penalty of thirteen (13) years, nine (9) months and eleven (11) days of reclusion temporal, as minimum, to sixteen (16) years, five (5) months and ten (10) days of reclusion temporal, as maximum.
	GR No. 182521 2011-02-09	PEOPLE v. ERNESTO FRAGANTE Y AYUDA CARPIO, J.
The Court is not impressed with appellant's claim that AAA's failure to immediately report the incidents to the proper authorities affected her credibility.[19] Delay could be attributed to the victim's tender age and the appellant's threats.[20] A rape victim's actions are oftentimes influenced by fear, rather than reason.[21] In incestuous rape, this fear is magnified because the victim usually lives under the same roof as the perpetrator or is at any rate subject to his dominance because of their blood relationship.[22]
	GR No. 189818 2010-08-09	PEOPLE v. MICHAEL LINDO Y VERGARA VELASCO JR., J.
That the act was carried out in a public place does not make it unbelievable. The evil in man has no conscience--the beast in him bears no respect for time and place, driving him to commit rape anywhere, even in places where people congregate such as in parks, along the roadside, within school premises, and inside a house where there are other occupants.[6] There is no rule that rape can only be committed in seclusion.[7] The commission of rape is not hindered by time or place as in fact it can be committed even in the most public of places.[8] Clearly, the argument of accused-appellant that there could be no rape as the place was in full view of the public does not have a legal leg to stand on. The fact that the area was in the public eye would not prevent a potential rapist from carrying out his criminal intent.
	GR No. 183577 2010-02-01	PEOPLE v. HILARIO ESCOTON DEL CASTILLO, J.
In this case, minor inconsistencies are expected because (1) "AAA" was a child witness, (2) she was made to testify on a painful and humiliating incident, (3) she was sexually assaulted several times, and (4) she was made to recount details and events that happened two years before she testified.[30]
	GR No. 183619 2009-10-13	PEOPLE v. SALVINO SUMINGWA NACHURA, J.
As the crime was committed by the father of the offended party, the alternative circumstance of relationship should be appreciated. In crimes against chastity, such as Acts of Lasciviousness, relationship is always aggravating.[51]
	GR No. 182454 2009-07-23	PEOPLE v. FELIX WASIT VELASCO JR., J.
We, thus, affirm the trial court's assessment of the testimonial evidence. First, the evaluation of the witnesses' credibility is, to repeat, a matter best left to the trial court because it has the opportunity to observe the witnesses and their demeanor during the trial. Thus, the Court accords great respect to the trial court's findings, unless it overlooked or misconstrued some facts of substance which could have affected the outcome of the case.[18] This rule finds an even more stringent application where the appellate court sustains the trial court's factual determination,[19] as here.
	GR No. 173052 2008-12-16	PEOPLE v. ROGELIO PELAGIO Y BERMUDO AUSTRIA-MARTINEZ, J.
The fact that it took a long time for AAA to report her father's transgressions does not mitigate her credibility. In the first place, appellant threatened to kill AAA and her mother.[19] Moreover, telling people that one has been raped by her own father is not easy to do, and a girl of AAA's age cannot be expected to know how to go about reporting crimes to the proper authorities.[20] Thus, the Court has constantly ruled that:x x x [D]elay in making a criminal accusation [does not] impair the credibility of a witness if such delay is satisfactorily explained. In People v. Coloma, x x x 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. In this case, [complainant] must have been overwhelmed by fear and confusion, and shocked that her own father had defiled her. x x x She also testified that she was afraid to tell her mother because the latter might be angered x x x. Indeed, a survey conducted by the University of the Philippines Center for Women's Studies showed that victims of rape committed by their fathers took much longer in reporting the incidents to the authorities than did other victims. Many factors account for this difference: the fact that the father lives with the victim and constantly exerts moral authority over her, the threat he might make against her, the victim's fear of her mother and other relatives.[21]
	GR No. 177354 2008-11-14	PEOPLE v. RICARDO TALAN Y DOE CARPIO, J.
An appeal in a criminal case opens the entire case for review. The Court can correct errors unassigned in the appeal.[7]
	GR No. 183696 2008-10-24	PEOPLE v. NELSON ARRAZ CARPIO, J.
While appellant admits kissing AAA on the lips around the time of the commission of the rape, appellant denies raping AAA. Appellant's flimsy denial cannot prevail over AAA's positive identification of appellant as the perpetrator of the crime. Moreover, appellant gravely failed to show material facts which the trial court overlooked or misunderstood and which could alter appellant's conviction. Well-settled is the rule that the Court accords great respect and full weight to the trial court's findings, unless the trial court overlooked substantial facts which could have affected the outcome of the case.[13] Appellant's claims involve minor or trifling matters that do not warrant a reversal of the decision of the lower courts.
	GR No. 176637 2008-10-06	PEOPLE v. REYNALDO DELA TORRE CARPIO, J.
An appeal in a criminal case opens the entire case for review. The Court can correct errors unassigned in the appeal.[7]

PEOPLE v. JOHN MONTINOLA