Lawyerly

GR No.178115

2014-07-28

DEL CASTILLO, J.

There is no reason to doubt Jerry and Mario's identification of the appellants considering that (1) Jerry was just six meters away from them;[16] (2) the moon was bright and Jerry was familiar with all the accused as most of them are his relatives;[17] and, (3) Mario knows Jojo ever since he was small.[18] Besides, "[t]ime-tested is the rule that between the positive assertions of prosecution witnesses and the negative averments of the accused, the former undisputedly [deserve] more credence and [are] entitled to greater evidentiary weight."[19]

GR No. 188352

2010-09-01

PEOPLE v. ROLLY DE GUZMAN

MENDOZA, J.

Without a doubt, the narration of AAA prevails over the bare denial and weak alibi of the accused. Self-serving statements cannot be accorded greater evidentiary weight than the declaration of a credible witness on affirmative matters. Time-tested is the rule that between the positive assertion of prosecution witnesses and the negative averment of an accused, the former undisputedly deserves more credence and is entitled to greater evidentiary value.[26]

GR No. 177152

2010-01-06

PEOPLE v. MANUEL BAGOS

LEONARDO-DE CASTRO, J.

Accused-appellant resorted to imputing ill-motives on the part of complainant's family and tried desperately to impress upon the Court that the case was instituted against him because of family grudge and in order to force him to shell out money to settle the instant case. We are unconvinced. Pertinently, we held in People v. Monteron[27] that: ...Not a few accused in rape cases have attributed the charges brought against them to family feud, resentment, or revenge. But such alleged motives have never swayed this Court from lending full credence to the testimony of the complainant where she remains steadfast in her direct and cross examination. Besides, no parent would expose his or her own daughter to the shame and scandal of having undergone such debasing defilement of her chastity if the charges were not true. It is unnatural for a parent to use his own offspring as an engine of malice, especially if it will subject a daughter to embarrassment and even stigma.

GR No. 185389

2009-07-07

PEOPLE v. BENJIE RESURRECCION

CHICO-NAZARIO, J.

In stark contrast to the damning evidence adduced by the prosecution, what Benjie could rally was only a defense of denial. Between the self-serving testimony of Benjie, uncorroborated by any witnesses or documents, and the positive declaration of the victim who was of tender age, the latter deserves greater credence. As the Court of Appeals pointed out, Benjie's baseless allegations -- that the charge of rape was prompted by his constant bickering with AAA and aggravated by her family's anger at his alleged stealing of P8,000.00 from the family business -- were too flimsy and beg the Court's credulity. Oft repeated is the truism that being a woman of tender age, shy and ignorant of the sophistication of a man's world, by no stretch of imagination can we believe that considering her innate modesty, humility and purity as a young Filipina, AAA would have permitted herself to be the object of public ridicule, shame and obloquy as a victim of sexual assault or debauchery.[21] It takes an extreme sense of moral depravity for a very young girl to accuse someone of a heinous crime, such as rape, and expose him to the perils attendant to a criminal conviction for such feeble reasons. No parent would expose his or her own daughter to the shame and scandal of having undergone such debasing defilement of her chastity if the charges were not true.[22] It is unnatural for a parent to use his own offspring as an engine of malice, especially if it will subject a daughter to embarrassment and even stigma.[23]

GR NO. 171020

2007-03-14

PEOPLE v. ALFREDO PANGILINAN Y TRINIDAD

CHICO-NAZARIO, J.

Arraignment is the formal mode and manner of implementing the constitutional right of an accused to be informed of the nature and cause of the accusation against him.[20] The purpose of arraignment is, thus, to apprise the accused of the possible loss of freedom, even of his life, depending on the nature of the crime imputed to him, or at the very least to inform him of why the prosecuting arm of the State is mobilized against him.[21]

GR Nos. 148804-06

2004-05-27

PEOPLE v. ORLANDO LIMIO Y QUEBRAL

QUISUMBING, J.

Appellant contends that the victim's mental retardation rendered her so susceptible to her mother's control and influence that she was coerced into filing fabricated rape charges against him. This contention is difficult to accept on its face. First, we note that appellant's stand on the complainant's mental condition is, to say the least, equivocal. On the one hand, he faults the prosecution for its failure to present expert medical evidence to prove beyond question her state of mental retardation. On the other, he characterizes her as mentally retarded and hence, highly subject to manipulation by her irate mother. His shifting views do not aid his cause. Second, his declaration that his wife bore him a grudge for his going out with his friend, the faith healer, appears to us less than convincing as a reason to accuse him falsely of so grave a crime as incestuous rape. No mother would expose a daughter to the shame and scandal of having undergone such a debasing defilement of her chastity if she did not believe the charges were true.[33] It is contrary to all human experience for a mother to use her daughter as an instrument of malice, especially if she will have to put her daughter in a position of shame and embarrassment, and cause her daughter a life-long stigma.

GR Nos. 134573-75

2003-10-23

PEOPLE v. VICENTE BINARAO

CORONA, J.

Indeed, Emma's testimony could not be struck down by appellants' bare defenses of denial and alibi. The positive assertions of Emma could not be overcome by the mere denial by appellants of their participation in the crime or by the mere alibi that they were not in the crime scene during the rape incident. Alibi as basis for acquittal must be established by clear and convincing evidence. Appellants failed to convincingly demonstrate that it was physically impossible for them to be at the scene of the crime at the time of its commission. On the other hand, the victim herself positively identified appellants as the perpetrators of the crime. Thus, the defense of alibi must fail.[39] Time-tested is the rule that between the positive assertions of the prosecution witness and the negative averments of the accused, the former undisputedly deserves more credence and is entitled to greater evidentiary value.[40] Thus, the trial court was correct in convicting appellants of the crimes charged.

GR No. 138366

2003-09-11

PEOPLE v. RUBEN CAÑETE

CORONA, J.

So long as the witnesses' testimonies agree on substantial matters, the inconsequential inconsistencies and contradictions dilute neither the witnesses' credibility nor the verity of their testimonies. When the inconsistency is not an essential element of the crime, such inconsistency is insignificant and can not have any bearing on the essential fact testified to, that is, the killing of the victim.[34] The time-tested rule is that, between the positive assertions of prosecution witnesses and the mere denials of the accused, the former undisputedly deserve more credence and are entitled to greater evidentiary value. [35] More so in this case where appellants failed to sufficiently explain why a shotgun was found at Sotero's hut or why Trinidad was found positive for gunpowder burns.

GR No. 134525

2003-02-28

PEOPLE v. ALFREDO DELOS SANTOS

AUSTRIA-MARTINEZ, J.

The imputation of the defense that Joy was prompted by her family to accuse herein appellant of the crime of rape because they could not evict the family of appellant from the property of Joy's grandmother, is completely outrageous and utterly desperate. This Court has noted that not a few accused in rape cases have attributed the charges brought against them to family feud, resentment, or revenge. But such allegations have never swayed this Court from lending full credence to the testimony of the complainant where she remains steadfast in her direct and cross examination.[48] It is unlikely for a young girl and her family to impute the crime of rape to another and face social humiliation if not to vindicate the honor of complainant. [49] Indeed, it is hard to fathom that parents would use their offsprings as engines of malice, especially if the same would subject them to humiliation and stigma.[50] Even as to grandparents, it is not believable that they who nurtured and loved the victim would expose an innocent girl to humiliation and stigma of a rape trial simply to get back at the accused.[51]

GR No. 140724-26

2003-02-12

PEOPLE v. ALLEN BUSTAMANTE

CORONA, J.

For his part, appellant merely offered the defense of alibi and denial which were uncorroborated by any positive testimony of the people who were allegedly with him during the incident. However, time-tested is the rule that between the positive assertions of prosecution witnesses and the negative averments of the appellant, the former undisputedly deserves more credence and are entitled to greater evidentiary value.[34] Thus, the positive assertions of the prosecution witnesses cannot be overcome by the mere denial of appellant or by mere alibi. For alibi to prosper, not only must appellant prove that he was at another place at the time of the commission of the crime, but also that it was physically impossible for him to be at the crime scene at that time.[35]

	GR No.178115 2014-07-28	PEOPLE OF PIDLIPPINES v. JOJO SUMILIDG DEL CASTILLO, J.
There is no reason to doubt Jerry and Mario's identification of the appellants considering that (1) Jerry was just six meters away from them;[16] (2) the moon was bright and Jerry was familiar with all the accused as most of them are his relatives;[17] and, (3) Mario knows Jojo ever since he was small.[18] Besides, "[t]ime-tested is the rule that between the positive assertions of prosecution witnesses and the negative averments of the accused, the former undisputedly [deserve] more credence and [are] entitled to greater evidentiary weight."[19]
	GR No. 188352 2010-09-01	PEOPLE v. ROLLY DE GUZMAN MENDOZA, J.
Without a doubt, the narration of AAA prevails over the bare denial and weak alibi of the accused. Self-serving statements cannot be accorded greater evidentiary weight than the declaration of a credible witness on affirmative matters. Time-tested is the rule that between the positive assertion of prosecution witnesses and the negative averment of an accused, the former undisputedly deserves more credence and is entitled to greater evidentiary value.[26]
	GR No. 177152 2010-01-06	PEOPLE v. MANUEL BAGOS LEONARDO-DE CASTRO, J.
Accused-appellant resorted to imputing ill-motives on the part of complainant's family and tried desperately to impress upon the Court that the case was instituted against him because of family grudge and in order to force him to shell out money to settle the instant case. We are unconvinced. Pertinently, we held in People v. Monteron[27] that: ...Not a few accused in rape cases have attributed the charges brought against them to family feud, resentment, or revenge. But such alleged motives have never swayed this Court from lending full credence to the testimony of the complainant where she remains steadfast in her direct and cross examination. Besides, no parent would expose his or her own daughter to the shame and scandal of having undergone such debasing defilement of her chastity if the charges were not true. It is unnatural for a parent to use his own offspring as an engine of malice, especially if it will subject a daughter to embarrassment and even stigma.
	GR No. 185389 2009-07-07	PEOPLE v. BENJIE RESURRECCION CHICO-NAZARIO, J.
In stark contrast to the damning evidence adduced by the prosecution, what Benjie could rally was only a defense of denial. Between the self-serving testimony of Benjie, uncorroborated by any witnesses or documents, and the positive declaration of the victim who was of tender age, the latter deserves greater credence. As the Court of Appeals pointed out, Benjie's baseless allegations -- that the charge of rape was prompted by his constant bickering with AAA and aggravated by her family's anger at his alleged stealing of P8,000.00 from the family business -- were too flimsy and beg the Court's credulity. Oft repeated is the truism that being a woman of tender age, shy and ignorant of the sophistication of a man's world, by no stretch of imagination can we believe that considering her innate modesty, humility and purity as a young Filipina, AAA would have permitted herself to be the object of public ridicule, shame and obloquy as a victim of sexual assault or debauchery.[21] It takes an extreme sense of moral depravity for a very young girl to accuse someone of a heinous crime, such as rape, and expose him to the perils attendant to a criminal conviction for such feeble reasons. No parent would expose his or her own daughter to the shame and scandal of having undergone such debasing defilement of her chastity if the charges were not true.[22] It is unnatural for a parent to use his own offspring as an engine of malice, especially if it will subject a daughter to embarrassment and even stigma.[23]
	GR NO. 171020 2007-03-14	PEOPLE v. ALFREDO PANGILINAN Y TRINIDAD CHICO-NAZARIO, J.
Arraignment is the formal mode and manner of implementing the constitutional right of an accused to be informed of the nature and cause of the accusation against him.[20] The purpose of arraignment is, thus, to apprise the accused of the possible loss of freedom, even of his life, depending on the nature of the crime imputed to him, or at the very least to inform him of why the prosecuting arm of the State is mobilized against him.[21]
	GR Nos. 148804-06 2004-05-27	PEOPLE v. ORLANDO LIMIO Y QUEBRAL QUISUMBING, J.
Appellant contends that the victim's mental retardation rendered her so susceptible to her mother's control and influence that she was coerced into filing fabricated rape charges against him. This contention is difficult to accept on its face. First, we note that appellant's stand on the complainant's mental condition is, to say the least, equivocal. On the one hand, he faults the prosecution for its failure to present expert medical evidence to prove beyond question her state of mental retardation. On the other, he characterizes her as mentally retarded and hence, highly subject to manipulation by her irate mother. His shifting views do not aid his cause. Second, his declaration that his wife bore him a grudge for his going out with his friend, the faith healer, appears to us less than convincing as a reason to accuse him falsely of so grave a crime as incestuous rape. No mother would expose a daughter to the shame and scandal of having undergone such a debasing defilement of her chastity if she did not believe the charges were true.[33] It is contrary to all human experience for a mother to use her daughter as an instrument of malice, especially if she will have to put her daughter in a position of shame and embarrassment, and cause her daughter a life-long stigma.
	GR Nos. 134573-75 2003-10-23	PEOPLE v. VICENTE BINARAO CORONA, J.
Indeed, Emma's testimony could not be struck down by appellants' bare defenses of denial and alibi. The positive assertions of Emma could not be overcome by the mere denial by appellants of their participation in the crime or by the mere alibi that they were not in the crime scene during the rape incident. Alibi as basis for acquittal must be established by clear and convincing evidence. Appellants failed to convincingly demonstrate that it was physically impossible for them to be at the scene of the crime at the time of its commission. On the other hand, the victim herself positively identified appellants as the perpetrators of the crime. Thus, the defense of alibi must fail.[39] Time-tested is the rule that between the positive assertions of the prosecution witness and the negative averments of the accused, the former undisputedly deserves more credence and is entitled to greater evidentiary value.[40] Thus, the trial court was correct in convicting appellants of the crimes charged.
	GR No. 138366 2003-09-11	PEOPLE v. RUBEN CAÑETE CORONA, J.
So long as the witnesses' testimonies agree on substantial matters, the inconsequential inconsistencies and contradictions dilute neither the witnesses' credibility nor the verity of their testimonies. When the inconsistency is not an essential element of the crime, such inconsistency is insignificant and can not have any bearing on the essential fact testified to, that is, the killing of the victim.[34] The time-tested rule is that, between the positive assertions of prosecution witnesses and the mere denials of the accused, the former undisputedly deserve more credence and are entitled to greater evidentiary value. [35] More so in this case where appellants failed to sufficiently explain why a shotgun was found at Sotero's hut or why Trinidad was found positive for gunpowder burns.
	GR No. 134525 2003-02-28	PEOPLE v. ALFREDO DELOS SANTOS AUSTRIA-MARTINEZ, J.
The imputation of the defense that Joy was prompted by her family to accuse herein appellant of the crime of rape because they could not evict the family of appellant from the property of Joy's grandmother, is completely outrageous and utterly desperate. This Court has noted that not a few accused in rape cases have attributed the charges brought against them to family feud, resentment, or revenge. But such allegations have never swayed this Court from lending full credence to the testimony of the complainant where she remains steadfast in her direct and cross examination.[48] It is unlikely for a young girl and her family to impute the crime of rape to another and face social humiliation if not to vindicate the honor of complainant. [49] Indeed, it is hard to fathom that parents would use their offsprings as engines of malice, especially if the same would subject them to humiliation and stigma.[50] Even as to grandparents, it is not believable that they who nurtured and loved the victim would expose an innocent girl to humiliation and stigma of a rape trial simply to get back at the accused.[51]
	GR No. 140724-26 2003-02-12	PEOPLE v. ALLEN BUSTAMANTE CORONA, J.
For his part, appellant merely offered the defense of alibi and denial which were uncorroborated by any positive testimony of the people who were allegedly with him during the incident. However, time-tested is the rule that between the positive assertions of prosecution witnesses and the negative averments of the appellant, the former undisputedly deserves more credence and are entitled to greater evidentiary value.[34] Thus, the positive assertions of the prosecution witnesses cannot be overcome by the mere denial of appellant or by mere alibi. For alibi to prosper, not only must appellant prove that he was at another place at the time of the commission of the crime, but also that it was physically impossible for him to be at the crime scene at that time.[35]

PEOPLE v. MARIANITO MONTERON Y PANTORAS