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PEOPLE v. PETRONILLO CASTILLO

This case has been cited 6 times or more.

2003-10-23
PER CURIAM
As to the first incident of rape on 6 June 1996, it was not impossible for appellant to commit sexual assault under the prevailing circumstances when the younger daughter was with the victim washing dishes. We take judicial notice of the fact, which may be considered of public knowledge, that the situs of the rape is not always or necessarily isolated or secluded.[15] It can be committed even in places where people congregate, in parks along the roadside, in school premises, in a house where there are other occupants, in the same room where other members of the family are also sleeping, and even in places which to many would appear unlikely and highly risky venues for its commission. There is no rule that rape can be committed only in seclusion.[16]
2003-09-10
VITUG, J.
Appellant contends that the prosecution has suppressed evidence in failing to present the affidavit of Melinda calling attention to the presumption that "evidence willfully suppressed would be adversed (sic) if produced." The contention is a futile attempt to invoke exoneration.  Ex-parte affidavits, which are often incomplete and inaccurate, are scarcely depended on and will certainly not prevail over credible statements of a witness on the stand,[6] particularly when the defense has had the full opportunity to cross-examine such a witness.
2001-03-27
MENDOZA, J.
In sum, what accused-appellant raises are issues of credibility, which are best left for determination by the trial court which had the opportunity of observing the behavior and demeanor of the witnesses while testifying.[49] Unless there are facts or circumstances of weight and influence which were misconstrued or overlooked by the trial court, its findings and conclusions concerning the credibility of witnesses must be accorded respect and should not be disturbed on appeal.[50]
2001-03-05
QUISUMBING, J.
These arguments lack merit. With respect to the discrepancy of the time of the rape, settled is the rule that in rape cases, the date or time of the incident is not an essential element of the offense and therefore need not be accurately stated.[19] Furthermore, inconsistencies between an affidavit and statements made in open court do not necessarily damage offended party's credibility, for affidavits are generally incomplete or even inaccurate and cannot be considered final repositories of truth.[20] As to appellant's assertion that the offended party's conduct after the alleged sexual assault is inconsistent with one who has supposedly just been raped, the rule is that there is no standard form of behavioral response when one is confronted with a strange or startling experience.[21] Otherwise put, nobody can exactly tell how a victim of sexual transgression is supposed to act or behave after her ordeal.
2001-02-28
PER CURIAM
We therefore see no cogent reason to doubt the complainant's credibility. It has long been established that the testimony of a rape victims, especially a child of tender years, is given full weight and credit.[50] A rape victim who testifies in a categorical, straightforward, spontaneous and frank manner, and remains consistent, is a credible witness.[51] Furthermore, this Court has repeatedly ruled that matters affecting credibility are best left to the trial court because of its unique opportunity to observe that elusive and incommunicable evidence of the witness' deportment on the stand while testifying, an opportunity denied the appellate courts which usually rely only on the cold pages of the mute records of the case.[52]
2000-10-06
YNARES-SANTIAGO, J.
It is thus imperative that the Information filed with the trial court be complete to the end that the accused may suitably prepare his defense. Corollary to this, an indictment must fully state the elements of the specific offense alleged to have been committed as it is the recital of the essentials of a crime which delineates the nature and cause of the accusation against the accused.[4] An information is sufficient as long as it states the statutory designation of the offense and the acts or omissions constituting the same.[5] It is likewise sufficient if the time averred is near the actual date as the information of the prosecuting officer will permit, and since that was done in this case, it was not shown that the time proved did not surprise or substantially prejudice the defense.[6]