PEOPLE VS. LIBRE
He further testified that Nia told
FACTS: Erlinda Racho, witness for the prosecution, testified that the
complainant Aida Genovia had been staying with them at Salmonan,
Quezon Boulevard, Davao City, since June, 1975 at the opening of the
classes. On November 5, 1975 she arrived at about 11:30 in the evening
and Racho noticed her hair to be disarranged, her dress dirty and torn.
When asked, the complainant started crying and informed her cousin that
she was raped by the accused. In the early morning of November 6, 1975,
while they were preparing to go out, Racho together with the complainant
saw the accused standing by a house located near their house in Salmonan,
Davao City. Because of the threat of the accused to kill her, it was only at
about 1:00 o'clock in the morning of November 6, that she, accompanied
by Genovia, went to the Davao City Police and on November 7 she again
escorted the complainant to the Davao Regional Hospital for examination.
ISSUE: Whether the trial court erred in giving full faith and credit to the
testimonies of the prosecution witnesses which he described as incredible,
biased, and unreliable
HELD: Well settled is the rule that when there is no showing of improper
motive on the part of the witnesses for testifying against the accused, the
fact that they are related to the victim does not render their clear and
positive testimony less worthy of full faith and credit. On the contrary,
their natural interest in securing the conviction of the guilty would deter
them from implicating persons other than the culprit, otherwise, the latter
would gain immunity.
PEOPLE VS. VILLANUEVA
FACTS: On December 5,1997, Reynaldo Gabuya received word that a
kissmark was on the neck of his younger sister, 11 year old Nia Gabuya. He
confronted and asked her who planted said kissmark. He was told that it
was their stepfather. He immediately brought his sister to the Pardo Police
Station and had the incident blottered. Upon the advice of the police
officer, Nia was brought to the hospital.
her that she was allegedly raped for the first time by Camilo Villanueva in
May 1997 and the last time was on December 4, 1997 at around 12:00
midnight. From May 1997 up to December 4, 1997 she has been sexually
abused by the appellant for seven times already.
ISSUE: Whether the testimony of the private complainant Nia Gabuya is
not tainted with material inconsistencies and grievous falsity.
HELD: Settled is the rule that discrepancies and inconsistencies on minor
matters neither impair the essential integrity of the prosecution’s evidence
as a whole nor reflect on the witness honesty. Such inconsistencies, which
may be caused by the natural fickleness of the memory, even tend to
strengthen rather than weaken the credibility of the witness because they
erase any suspicion of rehearsed testimony.
RCBC VS. BERNARDINO
FACTS: In 1995, Marcopper Mining Corporation (MMC) obtained an
unsecured bridge loan from RCBC in the amount of US$13.7 Million to
finance the acquisition of twelve (12) Rig Mining Trucks and one (1) Demag
Excavator Shovel. Payment of the bridge loan was supposed to be sourced
from the proceeds of a long term loan MMC was seeking from Export-
Import Bank (EXIM Bank). EXIM Bank, however, failed to approve the long
term loan due to a tailing spill in MMC's mining area in Marinduque which
caused the stoppage of MMC's operations.
ISSUE: Whether the CA blatantly disregarded the principle that
inconsistencies as to minor details and peripheral matters do not affect the
credibility of witnesses nor the probative weight of their testimonies.
HELD: While RCBC's witnesses may not have recalled certain details that
took place long before they were called to testify, they were clear on the
threshold legal and factual issues in this case. We have held that the failure
of a witness to recall each and every detail of an occurrence may even
serve to strengthen rather than weaken his credibility because it erases
any suspicion of a coached or rehearsed testimony.
ESTATE OF ROGELIO ONG VS. DIAZ(#25 in digests)
PEOPLE VS. BARON
FACTS: Baron resorted to a denial. He testified that at about 2:00 p.m. on
May 4, 1999, AAA joined him for a joy ride aboard his trisikad. At about
2:30 p.m., he turned over AAA to her mother in the presence of Gingging
Tacorda, Langging Tacorda, Soledad Palacios, and Romeo Inocencio. At
about 6:30 p.m., AAA’s mother approached him in the vicinity of Molo
Supermarket, asking about AAA’s whereabouts. He reminded her that he
had returned AAA to her. Romeo Inocencio asked him to go to the seawall,
where they found AAA’s lifeless body. He claimed to have learned of being
implicated in AAA’s rape and killing only after he was apprehended.
ISSUE: Whether the prosecution has established his involvement with
certainty.
HELD: As against these details and testimonies, all that accused-appellant
had offered in defense were denial and alibi—defenses that jurisprudence
has long considered weak and unreliable. It is hardly a relief to accused-
appellant that two (2) witnesses have testified in his defense. Even their
testimonies failed to definitively establish that accused-appellant neither
raped nor killed AAA. Defense witness Flordeliza Baron even admitted that
during the critical time between 5:00 and 6:00 p.m. of May 4, 1999, when
the rape and killing most likely took place, she was never really aware of
accused-appellant’s whereabouts.
PEOPLE VS. SOLINA
FACTS: Accused-appellant maintains her denial that she was engaged in
the business of recruiting possible workers for jobs abroad. She insists that
like all the private complainants, she was also an applicant for a job as an
overseas worker and that she merely accompanied them to a recruitment
agency. She alleges that private complainant Dela Vega and Dela Cruz
conspired together, used her name, and represented themselves to the
other applicants as being authorized to collect documents and fees and
that she only met the other private complainants in the trainings/seminars
she attended. Anent the acknowledgment receipt signed by her and
presented by the prosecution as evidence, accused-appellant argues that it
does not prove that the money received by her was the consideration for
private complainant Garces' placement abroad.
ISSUE: Whether the accused’s defense of denial should be taken into
consideration by the court
HELD: Accused-appellant's defense of denial cannot overcome the positive
testimonies of the witnesses presented by the prosecution.1avvphi1 As is
well-settled in this jurisdiction, greater weight is given to the positive
identification of the accused by the prosecution witnesses than the
accused's denial and explanation concerning the commission of the crime.
IBANEZ VS. PEOPLE
FACTS: Accused Emilio, for his part, interposed denial and alibi as his
defenses. He emphatically denied that he threw a stone at Rodolfo. On the
date and time of the incident, Emilio claimed that he was working overtime
as a laborer in Moonwalk, Las Pinas City, which is one kilometer away from
the crime scene. He argued that he was just unfortunately dragged into
this case which had nothing to do with him at all.
ISSUE: Whether the trial and appellate courts were right in not giving
probative value to petitioners' denial
HELD: Denial is an intrinsically weak defense that further crumbles when it
comes face-to-face with the positive identification and straightforward
narration of the prosecution witnesses. 46 Between an affirmative assertion
which has a ring of truth to it and a general denial, the former generally
prevails.
PALO VS. PEOPLE
FACTS: That on or about July 24, 2002 in Valenzuela City and within the
jurisdiction of this Honorable Court, the above-named accused, conspiring
together and mutually helping one another, without any authority of law,
did then and there wil[l]fully, unlawfully and feloniously have in their
possession, custody and control 0.03 gram of Methamphetamine
Hydrochloride (shabu), knowing the same to be a regulated drug.
ISSUE: Whether the lower courts were correct in rejecting accused’s
defense of denial
HELD: The lower courts correctly rejected petitioner's defense of denial for
being self-serving and uncorroborated. Denial is inherently a weak defense
which cannot outweigh positive testimony of a prosecution witness. 27 "A
defense of denial which is unsupported and unsubstantiated by clear and
convincing evidence becomes negative and self-serving, deserving no
weight in law, and cannot be given greater evidentiary value over
convincing, straightforward and probable testimony on affirmative
matters."
PEOPLE VS. EDA
FACTS: That on or about the 17th day of February, 2011, at about 5:00
o'clock in the afternoon, at Barangay Caloocan, Municipality of Balayan,
Province of Batangas, Philippines and within the jurisdiction of this
Honorable Court, the above-named accused, without authority of law, did
then and there willfully and unlawfully have in her (sic) possession, custody
and control four (4) heat-sealed transparent plastic sachets referred to as
specimens A-2 (RCB2) to A-5 (RCB5) in Chemistry Report No. BD-040-2011
each containing methamphetamine hydrochloride, commonly known as
"shabu'', having a total weight of 0.08 gram, a dangerous drug.
ISSUE: Whether the courts should consider accused’s defense of denial and
frame-up
HELD: The defense of denial and frame-up has been invariably viewed with
disfavor for it can easily be concocted and is a common and standard
defense ploy in prosecutions for violation of R.A. No. 9165. 36 In order to
prosper, the defense of denial and frame-up must be proved with strong
and convincing evidence.
FRANCO VS. PEOPLE
FACTS: That on or about November 3, 2004, in the City of Manila,
Philippines, the said accused did then and there willfully, unlawfully and
feloniously, with intent to gain and without the knowledge and consent of
the owner thereof, take, steal and carry away one (1) Nokia 3660 Model
cellular phone worth Php 18,500.00 belonging to BENJAMIN JOSEPH
NAKAMOTO Y ERGUIZA to the damage and prejudice of the said owner in
the aforesaid amount of Php 18,500.00
ISSUE: Whether the RTC and CA erred in relying heavily on circumstantial
evidence
HELD: Yes. In the appreciation of circumstantial evidence, the rule is that
the circumstances must be proved, and not themselves presumed. The
circumstantial evidence must exclude the possibility that some other
person has committed the offense charged. Franco, therefore, cannot be
convicted of the crime charged in this case. There is not enough evidence
to do so. As a rule, in order to support a conviction on the basis of
circumstantial evidence, all the circumstances must be consistent with the
hypothesis that the accused is guilty. In this case, not all the facts on which
the inference of guilt is based were proved. The matter of what and whose
cell phone Franco took from the altar still remains uncertain.
PEOPLE VS. URZAIS
FACTS: Accused-appellant, together with co-accused Alex Bautista and
Ricky Bautista, was charged with Violation of Republic Act (R.A.) No. 6539,
otherwise known as the Anti-Carnapping Act of 1972, as amended by R.A.
No. 7659, with homicide through the use of an unlicensed firearm.
ISSUE: Whether the lower courts erred in convicting the accused based on
circumstantial evidence
HELD: It is not only by direct evidence that an accused may be convicted,
but for circumstantial evidence to sustain a conviction, following are the
guidelines: (1) there is more than one circumstance; (2) the facts from
which the inferences are derived are proven; and (3) the combination of all
the circumstances is as such as to produce a conviction beyond reasonable
doubt.23 Decided cases expound that the circumstantial evidence
presented and proved must constitute an unbroken chain which leads to
one fair and reasonable conclusion pointing to the accused, to the
exclusion of all others, as the guilty person. All the circumstances must be
consistent with each other, consistent with the hypothesis that the
accused is guilty and at the same time inconsistent with the hypothesis
that he is innocent, and with every other rationale except that of guilt. In
the case at bar, notably there is only one circumstantial evidence. And this
sole circumstantial evidence of possession of the vehicle does not lead to
an inference exclusively consistent with guilt.
PEOPLE VS. QUITOLA
FACTS: That on or about March 15, 2008 at Nice Place Compound, Bgy.
Poblacion, [Urdaneta City,] Pangasinan, and within the jurisdiction of this
Honorable Court, the above-named accused, armed with a bladcd weapon,
with intent to gain by means of force and violence, did then and there
willfully, unlawfully and feloniously take, steal and rob Maria Fe Valencia y
Supan her cash money amounting to PHP6,000.00, one (I) Nokia Cellphone
and assorted jewelries against her will, and by reason or on the occasion of
the robbery, accused with intent to kill, did, then and there willfully,
unlawfully and feloniously with abuse of superior strength and
cruelty [stabbed] to death said Maria Fe Valencia y Supan, inflicting upon
her multiple stab wounds.
ISSUE: The defense argues that the circumstantial evidence relied upon by
the RTC were insufficient to establish accused-appellant's guilt
HELD: While there was no prosecution witness who positively identified
accused-appellant as the assailant, his culpability was nonetheless proven
through circumstantial evidence. Time and again, this Court has held that
direct evidence is not the only matrix wherefrom a trial court may draw its
conclusion and finding of guilt.24 The rules of evidence allow a trial court to
rely on circumstantial evidence to support its conclusion of guilt. At times,
resort to circumstantial evidence is imperative since to insist on direct
testimony would, in many cases, result in setting felons free and deny
proper protection to the community.
PEOPLE VS. PADIT
FACTS: That on or about the 5th day of May 2006, at about 12:00 noon,
Brgy. Naparaan, Salcedo, Eastern Samar, Philippines, within the jurisdiction
of this Honorable Court, the aforenamed accused with lewd design and by
means of force and intimidation, did then and there wilfully, unlawfully
and feloniously place and rub his penis into the vagina of [AAA], 4-year-old
girl minor, without her consent and against her will.
ISSUE: Accused-appellant's contends that the prosecution failed to prove
carnal knowledge on the ground that AAA explicitly stated in her testimony
that accused-appellant merely rubbed his penis against her vagina
HELD: Settled is the rule that testimonies of child-victims are normally
given full weight and credit, since when a girl, particularly if she is a minor,
says that she has been raped, she says in effect all that is necessary to
show that rape has, in fact, been committed.18 When the offended party is
of tender age and immature, courts are inclined to give credit to her
account of what transpired, considering not only her relative vulnerability
but also the shame to which she would be exposed if the matter to which
she testified is not true.19 Youth and immaturity are generally badges of
truth and sincerity.