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PEOPLE v. BERNALDO DOCDOC Y AUDITOR

This case has been cited 4 times or more.

2003-06-16
QUISUMBING, J.
The rule is that conviction for rape could be based on the lone testimony of the rape victim even in the absence of physical evidence to corroborate her claim.  But there is a proviso, that her testimony must be clear and free from serious contradictions and her sincerity and candor beyond suspicion.[42]  In this case, we find complainant's narration of the incident open to serious doubt.  There is no physical evidence of bruises or scratches, which would have spoken louder than words.[43] It is noteworthy that even when she and the appellants had arrived at the police station, she never breathed a word about a rape incident.  In fact, it was her father who filed a complaint for acts of lasciviousness against the appellants, not her.  When asked, on cross-examination, whether the appellants had sex with her, complainant meekly answered in the affirmative, showing neither disgust nor outrage, as would normally be expected of one whose honor had been violated.
2002-02-15
QUISUMBING, J.
As held in People vs. Docdoc,[37] the testimony of the offended party in a rape case should not be received with precipitate credulity for the charge can be easily concocted.  In any prosecution for rape the testimony of the complaining witness if credible would be sufficient to convict the accused.[38] Hence, the greatest degree of care and caution must be exercised before full faith and credit is given to complainant's testimony.  Basic is the rule that the testimonial evidence should come not only from the mouth of a credible witness but it should also be credible, reasonable, and in accord with human experience.[39]
2001-04-19
MENDOZA, J.
Accused-appellant contends that Sinclaire De Guzman's story is incredible and difficult to believe.  He stresses the fact that he has been blind for 20 years and that complainant could have simply pushed him away or easily escaped from his clutches had he really tried to rape her.  That she did not means that he did not even attempt to molest her.[20] We agree with accused-appellant. Courts are guided by the following principles in adjudging rape cases: (a) 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 the same; (b) 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; and (3) The evidence for the prosecution must stand or fall on its own merits and cannot be allowed to draw strength from the weakness of the evidence for the defense.[21] By the very nature of the crime, judgments in rape cases turn on the credibility of the complainant as only the participants can testify as to its occurrence.[22] In several cases,[23] we have held that the lone uncorroborated testimony of the complainant is sufficient to warrant a conviction, provided that such is credible, natural, convincing, and consistent with human nature and the normal course of things. However, we have also held that the testimony of the complainant should not be received with precipitate credulity but with the utmost caution.[24] The test for determining the credibility of complainant's testimony is whether it is in conformity with common knowledge and consistent with the experience of mankind. Whatever is repugnant to these standards becomes incredible and lies outside of judicial cognizance.[25] While we are mindful of the rule that the findings of the trial court regarding the credibility of witnesses are generally accorded great respect, and even finality, on appeal, this does not preclude a re-evaluation of the evidence to determine whether a fact or circumstance has not been overlooked or misinterpreted by the trial court.[26] We have not hesitated to reverse judgments of conviction where there are strong indications pointing to the possibility that the rape charge is false.[27] In this case, several circumstances lead us to doubt complainant's claim that she was raped by  accused-appellant.
2001-03-07
YNARES-SANTIAGO, J.
In People v. Docdoc,[17] it was stressed that:It is our ruling case law that the testimony of the offended party in crimes against chastity should not be received with precipitate credulity for the charge can be easily concocted. We exercise the greatest degree of care and caution before giving full faith and credit to the testimony of complainant. We have not hesitated to reverse judgments of conviction when there are strong indications pointing to the possibility that the rape charges are false. Nor have we sustained convictions when the complainant's conduct towards her alleged offender runs counter to human nature or appears uncharacteristic of a victim of such an abominable act. For the prosecution to succeed, it is imperative that the complainant's testimony be not only believable but must spring from the mouth of a credible witness which common experience can probe under the circumstances.[18] In rape cases, an accused may be convicted solely on the testimony of the complaining witness provided her testimony is credible, natural, convincing and consistent with human nature. Hence, the complainant's credibility becomes the single most important issue.[19]