This case has been cited 22 times or more.
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2015-07-22 |
PERALTA, J. |
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| It is true that in rape cases, the testimony of the victim is essential. However, when the victim is a small child or, as in this case, someone who acts like one, and thus cannot effectively testify as to the details of the offense, and there are no other eyewitnesses, resort to circumstantial evidence becomes inevitable. Circumstantial evidence, sometimes referred to as indirect or presumptive evidence, indirectly proves a fact in issue through an inference which the fact-finder draws from the evidence established.[19] It is not a weaker form of evidence vis-à-vis direct evidence.[20] Resort to it is imperative when the lack of direct testimony would result in setting an outlaw free. The Court reiterates that direct evidence of the commission of a crime is not the only basis on which a court may draw its finding of guilt.[21] In fact, circumstantial evidence, when demonstrated with clarity and forcefulness, may even be the sole basis of a criminal conviction. It cannot be overturned by bare denials or hackneyed alibis.[22] Established facts that form a chain of circumstances can lead the mind intuitively or impel a conscious process of reasoning towards a conviction. Verily, resort to circumstantial evidence is sanctioned by Section 5, Rule 133 of the Revised Rules on Evidence. The following are the requisites for circumstantial evidence to be sufficient to support conviction: (a) there is more than one (1) circumstance; (b) the facts from which the inferences are derived have been proven; and (c) the combination of all these circumstances results in a moral certainty that the accused, to the exclusion of all others, is the one who committed the crime. Thus, to justify a conviction based on circumstantial evidence, the combination of circumstances must be interwoven in such a way as to leave no reasonable doubt as to the guilt of the accused.[23] | |||||
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2013-02-20 |
PERLAS-BERNABE, J. |
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| Circumstantial evidence is defined as that evidence that indirectly proves a fact in issue through an inference which the fact-finder draws from the evidence established.[53] It is sufficient for conviction if: [a] there is more than one (1) circumstance; [b] the facts from which the inferences are derived are proven; and [c] the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.[54] | |||||
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2012-01-30 |
PERALTA, J. |
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| Appellate courts will generally not disturb the factual findings of the trial court since the latter has the unique opportunity to weigh conflicting testimonies, having heard the witnesses themselves and observed their deportment and manner of testifying,[24] unless attended with arbitrariness or plain disregard of pertinent facts or circumstances, the factual findings are accorded the highest degree of respect on appeal[25] as in the present case. | |||||
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2009-09-11 |
CHICO-NAZARIO, J. |
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| Simply, Loreto wants this Court to evaluate the credibility of the prosecution witnesses vis-a-vis the defense witness. It has often been said, however, that the credibility of witnesses is a matter best examined by, and left to, the trial courts. [27] The time-tested doctrine is that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[28] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses. [29] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court, unless it be manifestly shown that the trial court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[30] | |||||
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2009-08-04 |
CHICO-NAZARIO, J. |
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| Well-entrenched is the rule that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimonies in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[11] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court, unless it be manifestly shown that the lower courts had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[12] | |||||
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2008-12-24 |
CHICO-NAZARIO, J. |
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| Well-entrenched is the rule that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[27] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court, unless it be manifestly shown that the latter court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[28] The RTC and the Court of Appeals did not overlook any significant facts in the case. | |||||
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2008-12-04 |
CHICO-NAZARIO, J. |
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| Well-entrenched is the rule that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[28] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court unless it be manifestly shown that the trial court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[29] | |||||
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2008-10-17 |
CHICO-NAZARIO, J. |
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| In the main, petitioner wants this Court to evaluate the credibility of the prosecution witnesses vis-a-vis defense witnesses. It has often been said, however, that credibility of witnesses is a matter best examined by, and left to, the trial courts. [21] The time-tested doctrine is that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[22] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses. [23] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court unless it be manifestly shown that the latter court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[24] | |||||
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2008-08-26 |
CHICO-NAZARIO, J. |
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| (4) the offended party demands that the offender return the money or property.[8] Petitioner wants this Court to weigh the credibility of the prosecution witnesses vis-a-vis the defense witnesses. It has often been said, however, that the credibility of witnesses is a matter best examined by, and left to, the trial courts.[9] When the factual findings of the trial court are affirmed by the appellate court, the general rule applies.[10] This Court will not consider factual issues and evidentiary matters already passed upon. The petitioner raises the same issues she brought before the appellate court, which gave credence to the findings and decision of the trial court. | |||||
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2008-04-18 |
REYES, R.T., J. |
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| Circumstantial evidence is defined as that evidence that "indirectly proves a fact in issue through an inference which the fact-finder draws from the evidence established." Resort to it is essential when the lack of direct testimony would result in setting a felon free.[23] | |||||
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2008-03-28 |
CHICO-NAZARIO, J. |
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| The time-tested doctrine is that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[29] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses. [30] This is especially true when the trial court's findings have been affirmed by the appellate court, because said findings are generally conclusive and binding upon this Court unless it be manifestly shown that the lower courts had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[31] A scrutiny of the records shows that no such error was committed by either the RTC or the Court of Appeals. | |||||
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2008-03-28 |
CHICO-NAZARIO, J. |
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| In the main, petitioner wants this Court to weigh the credibility of the prosecution witnesses vis-a-vis that of the defense witnesses. It has often been said, however, that credibility of witnesses is a matter best examined by, and left to, the trial courts. [12] When the factual findings of the trial court are affirmed by the appellate court, the general rule applies.[13] This Court will not consider factual issues and evidentiary matters already passed upon. The petitioner raises the same issues he brought before the appellate court which gave credence to the findings and decision of the trial court. | |||||
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2008-03-28 |
REYES, R.T., J. |
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| free."[15] At the outset, We may well emphasize that direct evidence of the commission of a crime is not the only basis on which a court draws its finding of guilt. Established facts that form a chain of circumstances can lead the mind intuitively or impel a conscious process of | |||||
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2008-02-26 |
CHICO-NAZARIO, J. |
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| Well-entrenched is the rule that the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[43] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses, unless it be manifestly shown that the latter court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[44] | |||||
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2007-09-13 |
GARCIA, J. |
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| At the outset, we may well emphasize that direct evidence of the commission of a crime is not the only basis on which a court draws its finding of guilt, because established facts that form a chain of circumstances can lead the mind intuitively or impel a conscious process of reasoning towards a conviction.[15] Indeed, rules on evidence and principles in jurisprudence sustain the conviction of an accused through circumstantial evidence, defined as that which "indirectly proves a fact in issue through an inference which the fact-finder draws from the evidence established."[16] Resort thereto is essential when the lack of direct testimony would result in setting a felon free.[17] It is not a weaker form of evidence vis-a-vis direct evidence.[18] Cases have recognized that in its effect upon the courts, circumstantial evidence may surpass direct evidence in weight and probative force.[19] | |||||
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2007-09-03 |
CHICO-NAZARIO, J. |
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| In insisting that the trial court should not have given credence to the testimony of PO3 Bueno, appellant is basically making an issue about a witness's credibility. In this regard, we reiterate the rule that appellate courts will generally not disturb factual findings of the trial court since the latter has the unique opportunity to weigh conflicting testimonies, having heard the witnesses themselves and observed their deportment and manner of testifying.[24] Thus, unless attended with arbitrariness or plain disregard of pertinent facts or circumstances, the factual findings are accorded the highest degree of respect on appeal.[25] Our careful review of the records of this case reveals that the trial court did not err in relying on the testimony of PO3 Bueno. In open court, PO3 Bueno recounted their encounter with appellant as follows:PROS. LUNA: | |||||
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2007-08-17 |
CHICO-NAZARIO, J. |
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| The long-established rule is that, the matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[12] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses, unless it be manifestly shown that the latter court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[13] | |||||
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2007-04-24 |
CHICO-NAZARIO, J. |
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| Well-entrenched is the rule that the matter of assigning probative values to declarations on the witness stand is best and most competently performed by the trial judge who, unlike appellate magistrates, can weigh such testimony in light of the declarant's demeanor, conduct and position to discriminate between truth and falsehood.[9] Thus, appellate courts will not disturb the credence, or lack of it, accorded by the trial court to the testimonies of witnesses, unless it be manifestly shown that the latter court had overlooked or disregarded arbitrarily the facts and circumstances of significance in the case.[10] | |||||
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2006-12-06 |
CHICO-NAZARIO, J. |
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| Jurisprudence dictates that when the credibility of a witness is in issue, the findings of fact of trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded high respect if not conclusive effect.[40] This is because the trial court has the unique opportunity to observe the demeanor of a witness and is in the best position to discern whether they are telling the truth.[41] In the instant case, the RTC gave credence to the "vivid and detailed account of the incident" of the prosecution witnesses which according to it, "vibrates with truth and sincerity." It noted that the nature, number and location of the wounds sustained by Conrado bolstered the testimonies of the prosecution witnesses. It also found no improper motive on the part of the prosecution witnesses in testifying against appellant. | |||||
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2006-11-20 |
CHICO-NAZARIO, J. |
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| To reiterate, the RTC gave full faith and credence to the testimonies of the prosecution witnesses (private complainant, a certain Melanie Retiro and Monica) who all declared that the understated lists were the "sole handiwork" of petitioner since they are all very familiar with her handwriting as they were co-employees of the petitioner in the TBOS for number of years.[42] It noted that their testimonies were truthful because they were "unrehearsed, straightforward, categorical, natural and spontaneous."[43] In this regard, it should be borne in mind that the findings of fact of the trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded high respect if not conclusive effect.[44] This is because the trial court has the unique opportunity to observe the demeanor of a witness and is in the best position to discern whether they are telling the truth.[45] | |||||
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2006-09-27 |
CHICO-NAZARIO, J. |
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| It is a well-settled doctrine in our jurisprudence that when the credibility of a witness is in issue, the findings of fact of the trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded high respect if not conclusive effect.[29] This is because the trial court has the unique opportunity to observe the demeanor of a witness and is in the best position to discern whether they are telling the truth.[30] It is worth stressing at this point that the Court of Appeals affirmed such findings of the RTC. In this regard, it is settled that when the trial court's findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court.[31] We find no compelling reason to deviate from such findings of the RTC and the Court of Appeals. | |||||
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2006-04-18 |
PANGANIBAN, CJ |
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| That some pieces of the above-mentioned evidence are circumstantial does not diminish the fact that they are of a nature that would lead the mind intuitively, or by a conscious process of reasoning, toward the conviction of petitioner.[60] Circumstantial, vis-á-vis direct, evidence is not necessarily weaker.[61] Moreover, the circumstantial evidence described above satisfies the requirements of the Rules of Court, which we quote:"SEC. 4. Circumstantial evidence, when sufficient. --Circumstantial evidence is sufficient for conviction if: | |||||