Lawyerly

GR No. 167955

2009-09-30

PERALTA, J.

Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill-motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[62] In the present case, there is no showing of any improper motive on the part of the victim to testify falsely against the appellant or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists and that the testimony is worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.

GR No. 174484

2009-02-23

PEOPLE v. FELIX ORTOA Y OBIA

AUSTRIA-MARTINEZ, J.

Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[65] As earlier discussed, there is no showing of any improper motive on the part of the victims to testify falsely against the accused or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists, and that their testimonies are worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.

GR No. 168102

2008-08-22

PEOPLE v. JAYSON TUAZON Y OLIA

AUSTRIA-MARTINEZ, J.

Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[52] In the present case, there is no showing of any improper motive on the part of the victim to testify falsely against the accused or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists and that the testimony is worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.

GR Nos. 148743-45

2003-11-18

PEOPLE v. FELIX MONTES Y NALLOS

PANGANIBAN, J.

There is no standard form of behavior when one is confronted with a strange, startling or frightful event,[16] especially in the heinous crime of rape. It has long been recognized that the human mind works unpredictably when placed under emotional stress. [17] Rape victims have exhibited such an incalculable range of emotions that it is unrealistic to expect uniform reactions from them.[18] Hence, it is with good reason that the Court has not laid down any rule on how a rape victim should behave immediately after her ravishment.[19]

GR No. 135559

2003-09-18

PEOPLE v. MORENO OCUMEN Y MENDOZA

PER CURIAM

Our consistent pronouncement is that where, as here, the issue involves the assessment of credibility of witnesses, the reviewing court will not ordinarily disturb or set aside the findings of the trial court which gave due weight and credence to their testimonies. This is so because the trial court is in a better position to decide such issue, having personally heard the witnesses and observed their deportment and manner of testifying. Such findings are accorded finality, unless the trial court has overlooked certain substantial and valuable facts appearing in the record which, if considered, might alter the result of the case.[15]

GR No. 147033

2003-04-30

PEOPLE v. MARIO UMAYAM

PANGANIBAN, J.

The fact that private complainant slept after she was raped is not unusual or unnatural. Nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal. As we have already ruled in the past, it would not be too farfetched to suppose that, out of fear or a desire to forget the horror just committed upon her chastity, she slept soundly thereafter.[34]

GR No. 146458

2003-01-20

PEOPLE v. CAPT. MARCIAL LLANTO Y LEUTERIO

PUNO, J.

The accused cannot fault the trial court for relying on Cristy's sole eyewitness account in convicting him. This Court has long held that the testimony of a sole eyewitness is sufficient to support a conviction so long as it is clear, straightforward and worthy of credence by the trial court.[36] Neither does the self-serving evidence of the accused convince us that Cristy was merely instigated by her mother to file the rape complaint to extort his P500,000.00 retirement benefits. Nor does the imputation of Cristy's bad character affect her credibility as the victim's character is immaterial in a rape case.[37] Likewise, the testimonies of the defense witnesses on her alleged stealing are inconsistent and not worthy of credence. The accused testified that Cristy repeatedly stole money from him and his wife, but at the same time said that she was like a good daughter to them. His wife Felicitas, on the other hand, testified that Cristy was hard-headed and not nice and repeatedly stole money from her and her husband since she started living with them in 1993. Felicitas' sister, Dolores, stated that the accused and Felicitas spoke highly of Cristy as a good and obedient girl. Considering these inconsistent testimonies, we are not convinced with the accused's allegation that Cristy filed the rape charges in retaliation to his scolding her for stealing money and deciding to stop financing her schooling.

GR No. 137341

2002-10-28

PEOPLE v. SAMUEL B. BUADA

QUISUMBING, J.

multiple acts of sexual molestation. Her private parts were bruised and bleeding as a result of the successive rapes. In her weakened condition, immediate return to her home that night was out of the question. While it is true that the normal reaction of a rape victim is to take flight at the first opportunity so as to avoid her tormentors, and thus avoid risking a second rape,[49] nonetheless, it is also true that nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal.[50] The victim in this case was a mere youngster of 12 years. It is not proper to judge the actions of children who have undergone traumatic experiences by the norms of behavior expected from mature persons under similar circumstances.[51] A young girl cannot be expected to face the terrors of travel at night, more so when she is a long way from home. In rape cases, the essential element that the prosecution must prove is the absence of the victim's consent to the sexual congress. The gravamen of the crime of rape is sexual congress with a woman by force and without consent.[52] In the present case,

GR No. 137024

2002-08-07

PEOPLE v. ELOY MICLAT

KAPUNAN, J.

pursuant to Article 2219 of the Civil Code[88] without the necessity of additional pleading or proof other than the fact of rape.[89] Moral damages is granted in recognition of the victim's injury as being inherently concomitant with and necessarily resulting from the odious crime of rape, especially where the rape victim is an innocent child whose life is forever taunted by a foul and traumatic experience. [90] WHEREFORE, the assailed Decision of the Regional Trial Court, Marikina City, Branch 272 in Criminal Case No. 97-1871-MK finding appellant ELOY S. MICLAT guilty beyond reasonable doubt of the crime of rape and ordering him to pay to the offended party, MARY

GR Nos. 140642-46

2002-08-07

PEOPLE v. ROMEO

PER CURIAM

pursuant to Article 2219 of the Civil Code[88] without the necessity of additional pleading or proof other than the fact of rape.[89] Moral damages is granted in recognition of the victim's injury as being inherently concomitant with and necessarily resulting from the odious crime of rape, especially where the rape victim is an innocent child whose life is forever taunted by a foul and traumatic experience. [90] WHEREFORE, the assailed Decision of the Regional Trial Court, Marikina City, Branch 272 in Criminal Case No. 97-1871-MK finding appellant ELOY S. MICLAT guilty beyond reasonable doubt of the crime of rape and ordering him to pay to the offended party, MARY

	GR No. 167955 2009-09-30	PEOPLE v. ARMANDO PADILLA Y NICOLAS PERALTA, J.
Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill-motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[62] In the present case, there is no showing of any improper motive on the part of the victim to testify falsely against the appellant or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists and that the testimony is worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.
	GR No. 174484 2009-02-23	PEOPLE v. FELIX ORTOA Y OBIA AUSTRIA-MARTINEZ, J.
Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[65] As earlier discussed, there is no showing of any improper motive on the part of the victims to testify falsely against the accused or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists, and that their testimonies are worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.
	GR No. 168102 2008-08-22	PEOPLE v. JAYSON TUAZON Y OLIA AUSTRIA-MARTINEZ, J.
Against the overwhelming evidence of the prosecution, appellant merely interposed the defense of denial. Categorical and consistent positive identification, absent any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over the defense of denial.[52] In the present case, there is no showing of any improper motive on the part of the victim to testify falsely against the accused or to implicate him falsely in the commission of the crime; hence, the logical conclusion is that no such improper motive exists and that the testimony is worthy of full faith and credence. Accordingly, appellant's weak defense of denial cannot prosper.
	GR Nos. 148743-45 2003-11-18	PEOPLE v. FELIX MONTES Y NALLOS PANGANIBAN, J.
There is no standard form of behavior when one is confronted with a strange, startling or frightful event,[16] especially in the heinous crime of rape. It has long been recognized that the human mind works unpredictably when placed under emotional stress. [17] Rape victims have exhibited such an incalculable range of emotions that it is unrealistic to expect uniform reactions from them.[18] Hence, it is with good reason that the Court has not laid down any rule on how a rape victim should behave immediately after her ravishment.[19]
	GR No. 135559 2003-09-18	PEOPLE v. MORENO OCUMEN Y MENDOZA PER CURIAM
Our consistent pronouncement is that where, as here, the issue involves the assessment of credibility of witnesses, the reviewing court will not ordinarily disturb or set aside the findings of the trial court which gave due weight and credence to their testimonies. This is so because the trial court is in a better position to decide such issue, having personally heard the witnesses and observed their deportment and manner of testifying. Such findings are accorded finality, unless the trial court has overlooked certain substantial and valuable facts appearing in the record which, if considered, might alter the result of the case.[15]
	GR No. 147033 2003-04-30	PEOPLE v. MARIO UMAYAM PANGANIBAN, J.
The fact that private complainant slept after she was raped is not unusual or unnatural. Nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal. As we have already ruled in the past, it would not be too farfetched to suppose that, out of fear or a desire to forget the horror just committed upon her chastity, she slept soundly thereafter.[34]
	GR No. 146458 2003-01-20	PEOPLE v. CAPT. MARCIAL LLANTO Y LEUTERIO PUNO, J.
The accused cannot fault the trial court for relying on Cristy's sole eyewitness account in convicting him. This Court has long held that the testimony of a sole eyewitness is sufficient to support a conviction so long as it is clear, straightforward and worthy of credence by the trial court.[36] Neither does the self-serving evidence of the accused convince us that Cristy was merely instigated by her mother to file the rape complaint to extort his P500,000.00 retirement benefits. Nor does the imputation of Cristy's bad character affect her credibility as the victim's character is immaterial in a rape case.[37] Likewise, the testimonies of the defense witnesses on her alleged stealing are inconsistent and not worthy of credence. The accused testified that Cristy repeatedly stole money from him and his wife, but at the same time said that she was like a good daughter to them. His wife Felicitas, on the other hand, testified that Cristy was hard-headed and not nice and repeatedly stole money from her and her husband since she started living with them in 1993. Felicitas' sister, Dolores, stated that the accused and Felicitas spoke highly of Cristy as a good and obedient girl. Considering these inconsistent testimonies, we are not convinced with the accused's allegation that Cristy filed the rape charges in retaliation to his scolding her for stealing money and deciding to stop financing her schooling.
	GR No. 137341 2002-10-28	PEOPLE v. SAMUEL B. BUADA QUISUMBING, J.
multiple acts of sexual molestation. Her private parts were bruised and bleeding as a result of the successive rapes. In her weakened condition, immediate return to her home that night was out of the question. While it is true that the normal reaction of a rape victim is to take flight at the first opportunity so as to avoid her tormentors, and thus avoid risking a second rape,[49] nonetheless, it is also true that nobody can tell how a victim of sexual aggression is supposed to act or behave after her ordeal.[50] The victim in this case was a mere youngster of 12 years. It is not proper to judge the actions of children who have undergone traumatic experiences by the norms of behavior expected from mature persons under similar circumstances.[51] A young girl cannot be expected to face the terrors of travel at night, more so when she is a long way from home. In rape cases, the essential element that the prosecution must prove is the absence of the victim's consent to the sexual congress. The gravamen of the crime of rape is sexual congress with a woman by force and without consent.[52] In the present case,
	GR No. 137024 2002-08-07	PEOPLE v. ELOY MICLAT KAPUNAN, J.
pursuant to Article 2219 of the Civil Code[88] without the necessity of additional pleading or proof other than the fact of rape.[89] Moral damages is granted in recognition of the victim's injury as being inherently concomitant with and necessarily resulting from the odious crime of rape, especially where the rape victim is an innocent child whose life is forever taunted by a foul and traumatic experience. [90] WHEREFORE, the assailed Decision of the Regional Trial Court, Marikina City, Branch 272 in Criminal Case No. 97-1871-MK finding appellant ELOY S. MICLAT guilty beyond reasonable doubt of the crime of rape and ordering him to pay to the offended party, MARY
	GR Nos. 140642-46 2002-08-07	PEOPLE v. ROMEO PER CURIAM
pursuant to Article 2219 of the Civil Code[88] without the necessity of additional pleading or proof other than the fact of rape.[89] Moral damages is granted in recognition of the victim's injury as being inherently concomitant with and necessarily resulting from the odious crime of rape, especially where the rape victim is an innocent child whose life is forever taunted by a foul and traumatic experience. [90] WHEREFORE, the assailed Decision of the Regional Trial Court, Marikina City, Branch 272 in Criminal Case No. 97-1871-MK finding appellant ELOY S. MICLAT guilty beyond reasonable doubt of the crime of rape and ordering him to pay to the offended party, MARY

PEOPLE v. EMMANUEL QUEZADA