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PEOPLE VS. LIBRE 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
FACTS: Erlinda Racho, witness for the prosecution, testified that the May 1997 and the last time was on December 4, 1997 at around 12:00
complainant Aida Genovia had been staying with them at Salmonan, midnight. From May 1997 up to December 4, 1997 she has been sexually
Quezon Boulevard, Davao City, since June, 1975 at the opening of the abused by the appellant for seven times already.
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. ISSUE: Whether the testimony of the private complainant Nia Gabuya is
When asked, the complainant started crying and informed her cousin that not tainted with material inconsistencies and grievous falsity.
she was raped by the accused. In the early morning of November 6, 1975,
HELD: Settled is the rule that discrepancies and inconsistencies on minor
while they were preparing to go out, Racho together with the complainant
matters neither impair the essential integrity of the prosecution’s evidence
saw the accused standing by a house located near their house in Salmonan,
as a whole nor reflect on the witness honesty. Such inconsistencies, which
Davao City. Because of the threat of the accused to kill her, it was only at
may be caused by the natural fickleness of the memory, even tend to
about 1:00 o'clock in the morning of November 6, that she, accompanied
strengthen rather than weaken the credibility of the witness because they
by Genovia, went to the Davao City Police and on November 7 she again
erase any suspicion of rehearsed testimony.
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, RCBC VS. BERNARDINO
biased, and unreliable
FACTS: In 1995, Marcopper Mining Corporation (MMC) obtained an
HELD: Well settled is the rule that when there is no showing of improper unsecured bridge loan from RCBC in the amount of US$13.7 Million to
motive on the part of the witnesses for testifying against the accused, the finance the acquisition of twelve (12) Rig Mining Trucks and one (1) Demag
fact that they are related to the victim does not render their clear and Excavator Shovel. Payment of the bridge loan was supposed to be sourced
positive testimony less worthy of full faith and credit. On the contrary, from the proceeds of a long term loan MMC was seeking from Export-
their natural interest in securing the conviction of the guilty would deter Import Bank (EXIM Bank). EXIM Bank, however, failed to approve the long
them from implicating persons other than the culprit, otherwise, the latter term loan due to a tailing spill in MMC's mining area in Marinduque which
would gain immunity. 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
PEOPLE VS. VILLANUEVA
credibility of witnesses nor the probative weight of their testimonies.
FACTS: On December 5,1997, Reynaldo Gabuya received word that a
HELD: While RCBC's witnesses may not have recalled certain details that
kissmark was on the neck of his younger sister, 11 year old Nia Gabuya. He
took place long before they were called to testify, they were clear on the
confronted and asked her who planted said kissmark. He was told that it
threshold legal and factual issues in this case. We have held that the failure
was their stepfather. He immediately brought his sister to the Pardo Police
of a witness to recall each and every detail of an occurrence may even
Station and had the incident blottered. Upon the advice of the police
serve to strengthen rather than weaken his credibility because it erases PEOPLE VS. SOLINA
any suspicion of a coached or rehearsed testimony.
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
ESTATE OF ROGELIO ONG VS. DIAZ(#25 in digests)
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
PEOPLE VS. BARON other applicants as being authorized to collect documents and fees and
that she only met the other private complainants in the trainings/seminars
FACTS: Baron resorted to a denial. He testified that at about 2:00 p.m. on
she attended. Anent the acknowledgment receipt signed by her and
May 4, 1999, AAA joined him for a joy ride aboard his trisikad. At about
presented by the prosecution as evidence, accused-appellant argues that it
2:30 p.m., he turned over AAA to her mother in the presence of Gingging
does not prove that the money received by her was the consideration for
Tacorda, Langging Tacorda, Soledad Palacios, and Romeo Inocencio. At
private complainant Garces' placement abroad.
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 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. HELD: Accused-appellant's defense of denial cannot overcome the positive
testimonies of the witnesses presented by the prosecution.1avvphi1 As is
ISSUE: Whether the prosecution has established his involvement with well-settled in this jurisdiction, greater weight is given to the positive
certainty. identification of the accused by the prosecution witnesses than the
accused's denial and explanation concerning the commission of the crime.
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 IBANEZ VS. PEOPLE
testimonies failed to definitively establish that accused-appellant neither
FACTS: Accused Emilio, for his part, interposed denial and alibi as his
raped nor killed AAA. Defense witness Flordeliza Baron even admitted that
defenses. He emphatically denied that he threw a stone at Rodolfo. On the
during the critical time between 5:00 and 6:00 p.m. of May 4, 1999, when
date and time of the incident, Emilio claimed that he was working overtime
the rape and killing most likely took place, she was never really aware of
as a laborer in Moonwalk, Las Pinas City, which is one kilometer away from
accused-appellant’s whereabouts.
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 and control four (4) heat-sealed transparent plastic sachets referred to as
comes face-to-face with the positive identification and straightforward specimens A-2 (RCB2) to A-5 (RCB5) in Chemistry Report No. BD-040-2011
narration of the prosecution witnesses. 46 Between an affirmative assertion each containing methamphetamine hydrochloride, commonly known as
which has a ring of truth to it and a general denial, the former generally "shabu'', having a total weight of 0.08 gram, a dangerous drug.
prevails.
ISSUE: Whether the courts should consider accused’s defense of denial and
frame-up

PALO VS. PEOPLE 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
FACTS: That on or about July 24, 2002 in Valenzuela City and within the
defense ploy in prosecutions for violation of R.A. No. 9165. 36 In order to
jurisdiction of this Honorable Court, the above-named accused, conspiring
prosper, the defense of denial and frame-up must be proved with strong
together and mutually helping one another, without any authority of law,
and convincing evidence.
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.
FRANCO VS. PEOPLE
ISSUE: Whether the lower courts were correct in rejecting accused’s
FACTS: That on or about November 3, 2004, in the City of Manila,
defense of denial
Philippines, the said accused did then and there willfully, unlawfully and
HELD: The lower courts correctly rejected petitioner's defense of denial for feloniously, with intent to gain and without the knowledge and consent of
being self-serving and uncorroborated. Denial is inherently a weak defense the owner thereof, take, steal and carry away one (1) Nokia 3660 Model
which cannot outweigh positive testimony of a prosecution witness. 27 "A cellular phone worth Php 18,500.00 belonging to BENJAMIN JOSEPH
defense of denial which is unsupported and unsubstantiated by clear and NAKAMOTO Y ERGUIZA to the damage and prejudice of the said owner in
convincing evidence becomes negative and self-serving, deserving no the aforesaid amount of Php 18,500.00
weight in law, and cannot be given greater evidentiary value over
ISSUE: Whether the RTC and CA erred in relying heavily on circumstantial
convincing, straightforward and probable testimony on affirmative
evidence
matters."
HELD: Yes. In the appreciation of circumstantial evidence, the rule is that
the circumstances must be proved, and not themselves presumed. The
PEOPLE VS. EDA circumstantial evidence must exclude the possibility that some other
person has committed the offense charged. Franco, therefore, cannot be
FACTS: That on or about the 17th day of February, 2011, at about 5:00
convicted of the crime charged in this case. There is not enough evidence
o'clock in the afternoon, at Barangay Caloocan, Municipality of Balayan,
to do so. As a rule, in order to support a conviction on the basis of
Province of Batangas, Philippines and within the jurisdiction of this
circumstantial evidence, all the circumstances must be consistent with the
Honorable Court, the above-named accused, without authority of law, did
hypothesis that the accused is guilty. In this case, not all the facts on which
then and there willfully and unlawfully have in her (sic) possession, custody
the inference of guilt is based were proved. The matter of what and whose with intent to gain by means of force and violence, did then and there
cell phone Franco took from the altar still remains uncertain. 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
PEOPLE VS. URZAIS the robbery, accused with intent to kill, did, then and there willfully,
unlawfully and feloniously with abuse of superior strength and
FACTS: Accused-appellant, together with co-accused Alex Bautista and cruelty [stabbed] to death said Maria Fe Valencia y Supan, inflicting upon
Ricky Bautista, was charged with Violation of Republic Act (R.A.) No. 6539, her multiple stab wounds.
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: 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: While there was no prosecution witness who positively identified
accused-appellant as the assailant, his culpability was nonetheless proven
HELD: It is not only by direct evidence that an accused may be convicted, through circumstantial evidence. Time and again, this Court has held that
but for circumstantial evidence to sustain a conviction, following are the direct evidence is not the only matrix wherefrom a trial court may draw its
guidelines: (1) there is more than one circumstance; (2) the facts from conclusion and finding of guilt.24 The rules of evidence allow a trial court to
which the inferences are derived are proven; and (3) the combination of all rely on circumstantial evidence to support its conclusion of guilt. At times,
the circumstances is as such as to produce a conviction beyond reasonable resort to circumstantial evidence is imperative since to insist on direct
doubt.23 Decided cases expound that the circumstantial evidence testimony would, in many cases, result in setting felons free and deny
presented and proved must constitute an unbroken chain which leads to proper protection to the community.
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
PEOPLE VS. PADIT
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 FACTS: That on or about the 5th day of May 2006, at about 12:00 noon,
the case at bar, notably there is only one circumstantial evidence. And this Brgy. Naparaan, Salcedo, Eastern Samar, Philippines, within the jurisdiction
sole circumstantial evidence of possession of the vehicle does not lead to of this Honorable Court, the aforenamed accused with lewd design and by
an inference exclusively consistent with guilt. 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.
PEOPLE VS. QUITOLA
ISSUE: Accused-appellant's contends that the prosecution failed to prove
FACTS: That on or about March 15, 2008 at Nice Place Compound, Bgy. carnal knowledge on the ground that AAA explicitly stated in her testimony
Poblacion, [Urdaneta City,] Pangasinan, and within the jurisdiction of this that accused-appellant merely rubbed his penis against her vagina
Honorable Court, the above-named accused, armed with a bladcd weapon,
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.