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GR No. 202978

2016-02-01

PERALTA, J.

The Court is neither persuaded by accused-appellant's insistence that while there is no question - that children, like AAA, at such an age are incapable of lying, their credibility is not only limited to their capacity to tell the truth but also their capacity to grasp things that have happened, to intelligently recall them and to completely and accurately relate them. The fact that the offended party is a minor does not mean that she is incapable of perceiving and of making her perception known.[29] Children of sound mind are likely to be more observant of incidents which take place within their view than older persons, and their testimonies are likely more correct in detail than that of older persons.[30] In fact, AAA had consistently, positively, and categorically identified accused-appellant as her abuser. Her testimony was direct, candid, and replete with details of the rape.

GR No. 186494

2010-09-15

PEOPLE v. ROY ALCAZAR Y MIRANDA

PEREZ, J.

It is well-entrenched that a rape charge is a serious matter with pernicious consequences both for appellant and complainant; hence, utmost care must be taken in the review of a decision involving conviction of rape.[21] In the disposition and review of rape cases, therefore, this Court is guided by these well-established principles laid down in a catena of cases: (1) the prosecution has to show the guilt of the accused by proof beyond reasonable doubt or that degree of proof that, to an unprejudiced mind, produces conviction; (2) the evidence for the prosecution must stand or fall on its own merits and cannot draw strength from the weakness of the evidence of the defense; (3) unless there are special reasons, the findings of trial courts, especially regarding the credibility of witnesses, are entitled to great respect and will not be disturbed on appeal; (4) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; and (5) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution.[22]

GR No. 179714

2009-10-02

PEOPLE v. RODOLFO LOPEZ

PERALTA, J.

Since the trial judge had the direct and singular opportunity to observe the facial expression, gesture and tone of voice of the complaining witness while testifying, it was fully competent and in the best position to assess whether the witness was telling the truth.[22] This Court has also ruled that testimonies of victims of tender age are credible, more so if they are without any motive to falsely testify against their offender. Their revelations that they were raped, coupled with their willingness to undergo public trial where they could be compelled to describe the details of the assault on their dignity by their own father, cannot be easily dismissed as concoctions. It would be the height of moral and psychological depravity if they were to fabricate sordid tales of sexual defloration − which could put him behind bars for the rest of his life − if they were not true.[23]

GR No. 186379

2009-08-19

PEOPLE v. BIENVENIDO LAZARO

CHICO-NAZARIO, J.

Although the evidence is bereft of any indication that AAA, 11 years old during the incident, was coerced by the perpetrator, this fact cannot be utilized by the latter. This Court has held that if the woman is under twelve (12) years of age, proof of force and consent becomes immaterial, not only because force is not an element of statutory rape, but also because the absence of free consent is presumed when the woman is below 12 years old.[21] The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age.[22] Sexual congress with a girl under 12 years old is always rape.[23]

GR No. 185380

2009-06-18

PEOPLE v. ROGELIO MARCOS

CHICO-NAZARIO, J.

Statutory rape, under Article 266-A, par. 1-d, is committed by having carnal knowledge of a woman "when the offended party is under 12 years of age." The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[12]

GR No. 149785

2004-04-28

PEOPLE v. HENRY JUSAYAN Y SUGUI

QUISUMBING, J.

As provided for in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape.[24] The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman is below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[25]

GR No. 149370

2003-09-23

PEOPLE v. MARTIN ALEJO

YNARES-SANTIAGO, J.

Michelle's claim that she was raped by her stepfather is not only corroborated by the testimony of Simeon Balderama, but is also consistent with the findings of Dr. Danilo Balana that she had superficial multiple incomplete healed hymenal lacerations at 3, 9 and 11 o'clock positions. We have consistently held that when the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that the essential requisites of carnal knowledge has thereby been established.[19]

GR No. 131516

2003-03-05

PEOPLE v. RONNIE RULLEPA Y GUINTO

CARPIO MORALES, J.

That the Medical-Legal Officer found "no external signs of recent application of any form of trauma at the time of the examination" does not preclude accused-appellant's conviction since the infliction of force is immaterial in statutory rape.[23]

GR Nos. 139637-38

2003-01-22

PEOPLE v. MANUEL ESPERIDA

YNARES-SANTIAGO, J.

In addition, Dr. Umil's medical findings, presented to the court during trial, corroborated complainant's claim that she had been sexually violated by accused-appellant. When the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that essential requisites of carnal knowledge has thereby been established.[11]

GR No. 147943

2002-12-12

PEOPLE v. RICO B. BAGAUA

YNARES-SANTIAGO, J.

Rape is a serious offense with grave consequences both for the appellant and the complainant, hence the review of a judgment of conviction for rape must be done with utmost care.[5] In reviewing rape cases, we are guided with three settled principles,

GR No. 133582

2002-09-27

PEOPLE v. TEDDY ANGGIT

YNARES-SANTIAGO, J.

A rape charge is a serious matter with pernicious consequences both for the appellant and the complainant, hence utmost care must be taken in the review of a decision involving conviction for rape.[21] In reviewing rape cases, we are guided with

	GR No. 202978 2016-02-01	PEOPLE v. VICTOR P. PADIT PERALTA, J.
The Court is neither persuaded by accused-appellant's insistence that while there is no question - that children, like AAA, at such an age are incapable of lying, their credibility is not only limited to their capacity to tell the truth but also their capacity to grasp things that have happened, to intelligently recall them and to completely and accurately relate them. The fact that the offended party is a minor does not mean that she is incapable of perceiving and of making her perception known.[29] Children of sound mind are likely to be more observant of incidents which take place within their view than older persons, and their testimonies are likely more correct in detail than that of older persons.[30] In fact, AAA had consistently, positively, and categorically identified accused-appellant as her abuser. Her testimony was direct, candid, and replete with details of the rape.
	GR No. 186494 2010-09-15	PEOPLE v. ROY ALCAZAR Y MIRANDA PEREZ, J.
It is well-entrenched that a rape charge is a serious matter with pernicious consequences both for appellant and complainant; hence, utmost care must be taken in the review of a decision involving conviction of rape.[21] In the disposition and review of rape cases, therefore, this Court is guided by these well-established principles laid down in a catena of cases: (1) the prosecution has to show the guilt of the accused by proof beyond reasonable doubt or that degree of proof that, to an unprejudiced mind, produces conviction; (2) the evidence for the prosecution must stand or fall on its own merits and cannot draw strength from the weakness of the evidence of the defense; (3) unless there are special reasons, the findings of trial courts, especially regarding the credibility of witnesses, are entitled to great respect and will not be disturbed on appeal; (4) an accusation for rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; and (5) in view of the intrinsic nature of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution.[22]
	GR No. 179714 2009-10-02	PEOPLE v. RODOLFO LOPEZ PERALTA, J.
Since the trial judge had the direct and singular opportunity to observe the facial expression, gesture and tone of voice of the complaining witness while testifying, it was fully competent and in the best position to assess whether the witness was telling the truth.[22] This Court has also ruled that testimonies of victims of tender age are credible, more so if they are without any motive to falsely testify against their offender. Their revelations that they were raped, coupled with their willingness to undergo public trial where they could be compelled to describe the details of the assault on their dignity by their own father, cannot be easily dismissed as concoctions. It would be the height of moral and psychological depravity if they were to fabricate sordid tales of sexual defloration − which could put him behind bars for the rest of his life − if they were not true.[23]
	GR No. 186379 2009-08-19	PEOPLE v. BIENVENIDO LAZARO CHICO-NAZARIO, J.
Although the evidence is bereft of any indication that AAA, 11 years old during the incident, was coerced by the perpetrator, this fact cannot be utilized by the latter. This Court has held that if the woman is under twelve (12) years of age, proof of force and consent becomes immaterial, not only because force is not an element of statutory rape, but also because the absence of free consent is presumed when the woman is below 12 years old.[21] The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age.[22] Sexual congress with a girl under 12 years old is always rape.[23]
	GR No. 185380 2009-06-18	PEOPLE v. ROGELIO MARCOS CHICO-NAZARIO, J.
Statutory rape, under Article 266-A, par. 1-d, is committed by having carnal knowledge of a woman "when the offended party is under 12 years of age." The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman was below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[12]
	GR No. 149785 2004-04-28	PEOPLE v. HENRY JUSAYAN Y SUGUI QUISUMBING, J.
As provided for in the Revised Penal Code, sexual intercourse with a girl below 12 years old is statutory rape.[24] The two elements of statutory rape are: (1) that the accused had carnal knowledge of a woman; and (2) that the woman is below 12 years of age. Sexual congress with a girl under 12 years old is always rape.[25]
	GR No. 149370 2003-09-23	PEOPLE v. MARTIN ALEJO YNARES-SANTIAGO, J.
Michelle's claim that she was raped by her stepfather is not only corroborated by the testimony of Simeon Balderama, but is also consistent with the findings of Dr. Danilo Balana that she had superficial multiple incomplete healed hymenal lacerations at 3, 9 and 11 o'clock positions. We have consistently held that when the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that the essential requisites of carnal knowledge has thereby been established.[19]
	GR No. 131516 2003-03-05	PEOPLE v. RONNIE RULLEPA Y GUINTO CARPIO MORALES, J.
That the Medical-Legal Officer found "no external signs of recent application of any form of trauma at the time of the examination" does not preclude accused-appellant's conviction since the infliction of force is immaterial in statutory rape.[23]
	GR Nos. 139637-38 2003-01-22	PEOPLE v. MANUEL ESPERIDA YNARES-SANTIAGO, J.
In addition, Dr. Umil's medical findings, presented to the court during trial, corroborated complainant's claim that she had been sexually violated by accused-appellant. When the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that essential requisites of carnal knowledge has thereby been established.[11]
	GR No. 147943 2002-12-12	PEOPLE v. RICO B. BAGAUA YNARES-SANTIAGO, J.
Rape is a serious offense with grave consequences both for the appellant and the complainant, hence the review of a judgment of conviction for rape must be done with utmost care.[5] In reviewing rape cases, we are guided with three settled principles,
	GR No. 133582 2002-09-27	PEOPLE v. TEDDY ANGGIT YNARES-SANTIAGO, J.
A rape charge is a serious matter with pernicious consequences both for the appellant and the complainant, hence utmost care must be taken in the review of a decision involving conviction for rape.[21] In reviewing rape cases, we are guided with

PEOPLE v. WILFREDO SOMODIO