Lawyerly

GR No. 176354

2010-08-03

VILLARAMA, JR., J.

Jurisprudence teems with pronouncements that between the categorical statements of the prosecution witnesses, on the one hand, and the bare denial of appellants, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative one, especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[25]

GR No. 185726

2009-10-16

PEOPLE v. DARWIN BERNABE Y GARCIA

LEONARDO-DE CASTRO, J.

Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted.[32]

GR No. 185841

2009-08-04

PEOPLE v. ISMAEL DIAZ

CHICO-NAZARIO, J.

We agree with the Court of Appeals when it said that the credibility of said witnesses was not affected because it is well-settled that different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response when one is confronted with a strange or startling or frightful experience. Witnessing a crime is an unusual experience which elicits different reactions from the witnesses and for which no clear-cut standard form of behavior can be drawn.[55] As Arnel Quinto explained, he failed to call the attention of Councilor Quinto or SPO1 Dalioan because he did not know the intention of the appellants, and the incident happened very quickly, giving him no opportunity to give any warning to the councilor and to his security escort. Moreover, he was scared that he might get hit if he called the victims' attention.

GR No. 171085

2009-03-17

PEOPLE v. RODOLFO 'RUDY' SORIANO

QUISUMBING, J.

Appellant's argument that Genaro was impelled by ill motive to testify falsely against him must be rejected since the presence of personal motives on the part of a witness to testify in favor of the victim and against the accused should be supported by satisfactory proof before his testimony may be considered biased.[16] The records are barren of any satisfactory proof to show such bias on the part of Genaro.

GR No. 146696

2003-07-03

PEOPLE v. LEONILO PIDOY Y LANGRIO

YNARES-SANTIAGO, J.

The inconsistency is more apparent than real. In his direct examination, Pablo Brillantes estimated the time of appellant's arrival "at about 5:00 in the afternoon."[15] He did not say that appellant arrived at exactly 5:00 in the afternoon. It has been held that an error in the estimation of time is too immaterial to discredit the testimony of a witness, especially when time is not an essential element or has no substantial bearing on the fact of the commission of the offense.[16] This is a minor and insignificant detail that will not affect the finding that appellant perpetrated the crime.

GR No. 143004

2003-04-09

PEOPLE v. DANTE CLIDORO

YNARES-SANTIAGO, J.

Furthermore, it is the most natural reaction for victims of criminal violence to strive to ascertain the appearance of their attackers and observe the manner in which the crime was committed. Most often, the face and body movements of the assailants create a lasting impression on the victim's minds which cannot be easily erased from their memory.[15] Likewise, appellant failed to show that the prosecution witnesses were prompted by any ill motive to falsely testify or wrongfully accuse him of so grave a crime. In the absence of any evidence to show that the witness was actuated by any improper motive, his identification of the appellant as the author of the crime shall be given full faith and credit.[16]

GR No. 135682

2003-03-26

PEOPLE v. DANILO REYES Y BATAC

YNARES-SANTIAGO, J.

Accused-appellant faults the trial court for relying on the improbable testimony of PO1 Molato who testified that the victim upon seeing him ran away towards the direction where the two assailants also ran. It is well-settled that different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response where one is confronted with a strange or startling or frightful experience.[10] The firing of the warning shot may have frightened the victim and made him act the way he did, especially since PO1 Molato did not identify himself as a police officer before he fired the warning shot.

GR No. 147649

2002-12-17

PEOPLE v. FRANK LOBRIGAS

YNARES-SANTIAGO, J.

author of the crime to the exclusion of all others.[4] The rules on evidence and jurisprudence sustain the conviction of an accused through circumstantial evidence when the following requisites concur: (1) there is more than one circumstance; (2) the inference must be based on proven facts; and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.[5] The circumstances proved by the prosecution and relied upon by the trial court to convict accused-appellant clearly satisfied the foregoing requirements. First, the victim, accused appellant and others were together having a drinking spree on the day the mauling

GR No. 139472

2002-11-27

PEOPLE v. RAUL GUIMBA Y RUBA

YNARES-SANTIAGO, J.

evidence to show that the witness was actuated by any improper motive, his identification of the accused as the assailant should be given full faith and credit.[9] The fact that there was no cartographic sketch of the perpetrators made immediately after the incident does not in any way lessen the credibility of the prosecution's witnesses for it is neither an indispensable requirement in prosecuting the crime nor is it an element

GR No. 138782

2002-09-27

PEOPLE v. JERRY VILLEGAS

YNARES-SANTIAGO, J.

clearly arbitrary or unfounded. The rationale for this doctrine is that "the trial judge is able to detect that sometimes thin line between fact and prevarication that will determine the guilt and innocence of the accused. That line may not be discernible from a mere reading of the impersonal records by the reviewing court. The record will not reveal those tell-tale signs that will affirm the truth or expose the contrivance, like the angry flush of an insisted assertion or the sudden pallor of a discovered lie or the tremulous mutter of a reluctant answer or the forthright tone of a ready reply. The record will not show if the eyes have darted in evasion or looked down in confession or gazed steadily with a serenity that has nothing to distort or conceal. The record will not show if tears were shed in anger, or in shame, or in remembered pain, or in feigned innocence. Only the judge trying the case can see all these and on the basis of his observations arrive at an informed and reasoned verdict."[15] Well settled is the rule that the findings of facts and assessment of credibility of witnesses is a matter best left to the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while

GR No. 138647

2002-09-27

PEOPLE v. MARLON BULFANGO Y PEÑAFIEL

YNARES-SANTIAGO, J.

categorical statements of the prosecution witnesses, on the one hand, and the bare denial of accused-appellant, on the other hand, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when the former comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. It is considered with suspicion and always received with caution, not only because it is inherently weak and unreliable but also because it is easily fabricated and concocted.[8] Moreover, for alibi to prevail, it must be established by positive, clear and satisfactory proof that it was physically impossible for the accused to have been at the scene of the crime at the time of the commission, and not merely that he was somewhere else.

GR No. 145712

2002-09-24

PEOPLE v. VICTOR HATE

YNARES-SANTIAGO, J.

actuated by any improper motive, his identification of the assailant should be given full faith and credit.[17] Moreover, the witnesses need not know the names of the accused as long as they recognize their faces. What is important is that the witnesses are positive as to the perpetrators' physical identification from the witnesses' own personal knowledge.[18]

GR No. 128593

2002-08-14

PEOPLE v. ZENAIDA MANALAD

YNARES-SANTIAGO, J.

P50,000.00. The purpose for such award is to compensate the heirs of the victim for injuries to their feelings and not to enrich them.[23] Finally, the award of P13,000.00 for funeral expenses must be deleted. It appears that said amount was based on the contract for funeral services.[24] However, a contract for funeral services is not proof that what was stipulated in the contract was eventually paid. Hence, the contract cannot be considered as proof of the amount of the loss.[25] WHEREFORE, in view of the foregoing, the decision of the Regional Trial Court of Caloocan City, Branch 121, in Criminal Case No. C-47707, is MODIFIED. Accused-appellant is declared GUILTY beyond reasonable doubt of the crime of Homicide and is sentenced to

GR No. 140426

2002-07-30

PEOPLE v. EDDIE ANDARME

YNARES-SANTIAGO, J.

arbitrary or unfounded. The rationale for this doctrine, as explained in People v. Cayabyab, is that "the trial judge is able to detect that sometimes thin line between fact and prevarication that will determine the guilt and innocence of the accused. That line may not be discernible from a mere reading of the impersonal records by the reviewing court. The record will not reveal those tell-tale signs that will affirm the truth or expose the contrivance, like the angry flush of an insisted assertion or the sudden pallor of a discovered lie or the tremulous mutter of a reluctant answer or the forthright tone of a ready reply. The record will not show if tears were shed in anger, or in shame, or in remembered pain, or in feigned innocence. Only the judge trying the case can see all these and on the basis of his observations arrive at an informed and reasoned verdict."[13] Hence, well-settled is the rule that the findings of facts and assessment of credibility of witnesses is a matter best left to the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand

	GR No. 176354 2010-08-03	PEOPLE v. WILSON LOPEZ VILLARAMA, JR., J.
Jurisprudence teems with pronouncements that between the categorical statements of the prosecution witnesses, on the one hand, and the bare denial of appellants, on the other, the former must perforce prevail. An affirmative testimony is far stronger than a negative one, especially when it comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable, but also because they are easily fabricated and concocted.[25]
	GR No. 185726 2009-10-16	PEOPLE v. DARWIN BERNABE Y GARCIA LEONARDO-DE CASTRO, J.
Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. They are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted.[32]
	GR No. 185841 2009-08-04	PEOPLE v. ISMAEL DIAZ CHICO-NAZARIO, J.
We agree with the Court of Appeals when it said that the credibility of said witnesses was not affected because it is well-settled that different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response when one is confronted with a strange or startling or frightful experience. Witnessing a crime is an unusual experience which elicits different reactions from the witnesses and for which no clear-cut standard form of behavior can be drawn.[55] As Arnel Quinto explained, he failed to call the attention of Councilor Quinto or SPO1 Dalioan because he did not know the intention of the appellants, and the incident happened very quickly, giving him no opportunity to give any warning to the councilor and to his security escort. Moreover, he was scared that he might get hit if he called the victims' attention.
	GR No. 171085 2009-03-17	PEOPLE v. RODOLFO 'RUDY' SORIANO QUISUMBING, J.
Appellant's argument that Genaro was impelled by ill motive to testify falsely against him must be rejected since the presence of personal motives on the part of a witness to testify in favor of the victim and against the accused should be supported by satisfactory proof before his testimony may be considered biased.[16] The records are barren of any satisfactory proof to show such bias on the part of Genaro.
	GR No. 146696 2003-07-03	PEOPLE v. LEONILO PIDOY Y LANGRIO YNARES-SANTIAGO, J.
The inconsistency is more apparent than real. In his direct examination, Pablo Brillantes estimated the time of appellant's arrival "at about 5:00 in the afternoon."[15] He did not say that appellant arrived at exactly 5:00 in the afternoon. It has been held that an error in the estimation of time is too immaterial to discredit the testimony of a witness, especially when time is not an essential element or has no substantial bearing on the fact of the commission of the offense.[16] This is a minor and insignificant detail that will not affect the finding that appellant perpetrated the crime.
	GR No. 143004 2003-04-09	PEOPLE v. DANTE CLIDORO YNARES-SANTIAGO, J.
Furthermore, it is the most natural reaction for victims of criminal violence to strive to ascertain the appearance of their attackers and observe the manner in which the crime was committed. Most often, the face and body movements of the assailants create a lasting impression on the victim's minds which cannot be easily erased from their memory.[15] Likewise, appellant failed to show that the prosecution witnesses were prompted by any ill motive to falsely testify or wrongfully accuse him of so grave a crime. In the absence of any evidence to show that the witness was actuated by any improper motive, his identification of the appellant as the author of the crime shall be given full faith and credit.[16]
	GR No. 135682 2003-03-26	PEOPLE v. DANILO REYES Y BATAC YNARES-SANTIAGO, J.
Accused-appellant faults the trial court for relying on the improbable testimony of PO1 Molato who testified that the victim upon seeing him ran away towards the direction where the two assailants also ran. It is well-settled that different people react differently to a given situation or type of situation, and there is no standard form of human behavioral response where one is confronted with a strange or startling or frightful experience.[10] The firing of the warning shot may have frightened the victim and made him act the way he did, especially since PO1 Molato did not identify himself as a police officer before he fired the warning shot.
	GR No. 147649 2002-12-17	PEOPLE v. FRANK LOBRIGAS YNARES-SANTIAGO, J.
author of the crime to the exclusion of all others.[4] The rules on evidence and jurisprudence sustain the conviction of an accused through circumstantial evidence when the following requisites concur: (1) there is more than one circumstance; (2) the inference must be based on proven facts; and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.[5] The circumstances proved by the prosecution and relied upon by the trial court to convict accused-appellant clearly satisfied the foregoing requirements. First, the victim, accused appellant and others were together having a drinking spree on the day the mauling
	GR No. 139472 2002-11-27	PEOPLE v. RAUL GUIMBA Y RUBA YNARES-SANTIAGO, J.
evidence to show that the witness was actuated by any improper motive, his identification of the accused as the assailant should be given full faith and credit.[9] The fact that there was no cartographic sketch of the perpetrators made immediately after the incident does not in any way lessen the credibility of the prosecution's witnesses for it is neither an indispensable requirement in prosecuting the crime nor is it an element
	GR No. 138782 2002-09-27	PEOPLE v. JERRY VILLEGAS YNARES-SANTIAGO, J.
clearly arbitrary or unfounded. The rationale for this doctrine is that "the trial judge is able to detect that sometimes thin line between fact and prevarication that will determine the guilt and innocence of the accused. That line may not be discernible from a mere reading of the impersonal records by the reviewing court. The record will not reveal those tell-tale signs that will affirm the truth or expose the contrivance, like the angry flush of an insisted assertion or the sudden pallor of a discovered lie or the tremulous mutter of a reluctant answer or the forthright tone of a ready reply. The record will not show if the eyes have darted in evasion or looked down in confession or gazed steadily with a serenity that has nothing to distort or conceal. The record will not show if tears were shed in anger, or in shame, or in remembered pain, or in feigned innocence. Only the judge trying the case can see all these and on the basis of his observations arrive at an informed and reasoned verdict."[15] Well settled is the rule that the findings of facts and assessment of credibility of witnesses is a matter best left to the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand while
	GR No. 138647 2002-09-27	PEOPLE v. MARLON BULFANGO Y PEÑAFIEL YNARES-SANTIAGO, J.
categorical statements of the prosecution witnesses, on the one hand, and the bare denial of accused-appellant, on the other hand, the former must perforce prevail. An affirmative testimony is far stronger than a negative testimony especially when the former comes from the mouth of a credible witness. Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law. It is considered with suspicion and always received with caution, not only because it is inherently weak and unreliable but also because it is easily fabricated and concocted.[8] Moreover, for alibi to prevail, it must be established by positive, clear and satisfactory proof that it was physically impossible for the accused to have been at the scene of the crime at the time of the commission, and not merely that he was somewhere else.
	GR No. 145712 2002-09-24	PEOPLE v. VICTOR HATE YNARES-SANTIAGO, J.
actuated by any improper motive, his identification of the assailant should be given full faith and credit.[17] Moreover, the witnesses need not know the names of the accused as long as they recognize their faces. What is important is that the witnesses are positive as to the perpetrators' physical identification from the witnesses' own personal knowledge.[18]
	GR No. 128593 2002-08-14	PEOPLE v. ZENAIDA MANALAD YNARES-SANTIAGO, J.
P50,000.00. The purpose for such award is to compensate the heirs of the victim for injuries to their feelings and not to enrich them.[23] Finally, the award of P13,000.00 for funeral expenses must be deleted. It appears that said amount was based on the contract for funeral services.[24] However, a contract for funeral services is not proof that what was stipulated in the contract was eventually paid. Hence, the contract cannot be considered as proof of the amount of the loss.[25] WHEREFORE, in view of the foregoing, the decision of the Regional Trial Court of Caloocan City, Branch 121, in Criminal Case No. C-47707, is MODIFIED. Accused-appellant is declared GUILTY beyond reasonable doubt of the crime of Homicide and is sentenced to
	GR No. 140426 2002-07-30	PEOPLE v. EDDIE ANDARME YNARES-SANTIAGO, J.
arbitrary or unfounded. The rationale for this doctrine, as explained in People v. Cayabyab, is that "the trial judge is able to detect that sometimes thin line between fact and prevarication that will determine the guilt and innocence of the accused. That line may not be discernible from a mere reading of the impersonal records by the reviewing court. The record will not reveal those tell-tale signs that will affirm the truth or expose the contrivance, like the angry flush of an insisted assertion or the sudden pallor of a discovered lie or the tremulous mutter of a reluctant answer or the forthright tone of a ready reply. The record will not show if tears were shed in anger, or in shame, or in remembered pain, or in feigned innocence. Only the judge trying the case can see all these and on the basis of his observations arrive at an informed and reasoned verdict."[13] Hence, well-settled is the rule that the findings of facts and assessment of credibility of witnesses is a matter best left to the trial court because of its unique position of having observed that elusive and incommunicable evidence of the witnesses' deportment on the stand

PEOPLE v. MANUEL BANIEGA Y MORALES