PEOPLE VS. LIBRE FACTS: Erlinda Racho, witness for the prosecution, testified that the complainant Aida Genovia had been staying with them at S almonan, 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 s he, 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.
officer, Nia was brought to the hospital. He further testified that Nia told 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 p rosecution’s evidence as a whole nor reflect on the witness honesty. Such inconsistencies, which may be caused by the natural fickleness o f the memory, even tend to strengthen rather than weaken the credibility of the witness because they erase any suspicion of rehearsed testimony.
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 victi m 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 t he culprit, otherwise, the latter would gain immunity.
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 s upposed to be sourced from the proceeds of a long term loan MMC was seeking from ExportImport 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 t hat
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
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
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.
Supermarket, asking about AAA’s whe reabouts. He reminded her that he
ISSUE: Whether the accused’s defense of denial should be taken into
had returned AAA to her. Romeo Inocencio asked him to go to the seawall,
consideration by the court
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 accusedappellant 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.
HELD: Accused-appellant's defense of denial cannot overcome the positi ve
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.
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 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."
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
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
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.
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 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,
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 f ailed 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.
