Credibility of Witnesses

Credibility of — Absent any showing that the trial judge acted arbitrarily, or overlooked, misunderstood, or misapplied some facts or circumstances of weight which would affect the result of the case, his assessment of the credibility of witnesses deserves high respect by the appellate court. (People vs. Arcenal, G.R. No. 216015, Mar. 27, 2017)

—      Although there may be inconsistencies on minor details, the same do not impair the credibility of the witnesses where there is consistency in relating the principal occurrence and positive identification of the accused; theseinconsistencies are minor and inconsequential which even tend to bolster, rather than weaken, the credibility of the witnesses, for they show that such testimonies were not contrived or rehearsed. (People vs. Ohayas, G.R. No. 207516, June 19, 2017)

—      As a general rule, on the question of whether to believe the version of the prosecution or that of the defense, the trial court’s choice is generally viewed as correct and entitled to the highest respect because it is more competent to conclude so, having had the opportunity to observe the witnesses’ demeanor and deportment on the witness stand as they gave their testimonies. (People vs. Amoc, G.R. No. 216937, June 05, 2017)

—      As to appellant’s contention that the testimony of victim is full of inconsistencies and, hence, should not be given credence, this Court has ruled that discrepancies referring only to minor details and collateral matters do not affect the veracity or do not detract from the essential credibility of a witness’ declarations, as long as these are coherent and intrinsically believable on the whole. (People vs. Bentayo, G.R. No. 216938, June 05, 2017)

—      Delay in reporting an incident of rape is not an indication of fabrication and does not necessarily cast doubt on the credibility of the complainant; only when the delay is unreasonable or unexplained may it work to discredit the complainant. (People vs. Bisora, G.R. No. 218942, June 05, 2017)

—      Factual findings of the trial court and its evaluation of the credibility of witnesses and their testimonies are entitled to great respect and will not be disturbed on appeal, unless the trial court is shown to have overlooked, misapprehended, or misapplied any fact or circumstance of weight and substance. (People vs. Entrampas, G.R. No. 212161, Mar. 29, 2017)

          (People vs. Ambatang, G.R. No. 205855, Mar. 29, 2017)

—      Factual findings of the trial court and its observation as to the testimonies of the witnesses are accorded great respect, if not conclusive effect, most especially when affirmed by the Court of Appeals, as in this case; rationale. (People vs. Dela Cruz, G.R. No. 214500, June 28, 2017)

—      Factual findings of the trial court, its assessment of the credibility of witnesses and the probative weight of their testimonies and the conclusions based on these factual findings are to be given the highest respect. (People vs. Hirang, G.R. No. 223528, Jan. 11, 2017)

—      Findings of the trial court concurred with by the Court of Appeals, respected; the rule is even more strictly applied if the appellate court has concurred with the trial court as in this case. (People vs. Alberca, G.R. No. 217459, June 07, 2017)

—      Findings of the trial court on the credibility of witnesses deserve great weight. (People vs. Umapas, G.R. No. 215742, Mar. 22, 2017)

—      Guidelines in identification of accused through photographs are necessary considering that the out-of-court identification of an accused is susceptible to suggestiveness; these paramaters are in place to make the identification of the accused as objective as possible; application. (Escalante vs. People, G.R. No. 218970, June 28, 2017)

—      Her failures to resist the sexual aggression and to immediately report the incident to the authorities or to her mother do not undermine her credibility; the silence of the rape victim does not negate her sexual molestation or make her charge baseless, untrue, or fabricated; minor cannot be expected to act like an adult or a mature experienced woman who would have the courage and intelligence to disregard the threat to her life and complain immediately that she had been sexually assaulted. (People vs. Entrampas, G.R. No. 212161, Mar. 29, 2017)

—      In assessing the credibility of witnesses, the Court gives great respect to the evaluation of the trial court for it had the unique opportunity to observe the demeanour of witnesses and their deportment on the witness stand, an opportunity that is unavailable to the appellate courts, which simply rely on the cold records of the case. (Lavarez vs. Guevarra, G.R. No. 206103, Mar. 29, 2017)

—      In cases involving violations of the Dangerous Drugs Act, credence should be given to the narration of the incident by the prosecution witnesses especially when they are police officers who are presumed to have performed their duties in a regular manner, unless there is evidence to the contrary. (People vs. Alacdis, G.R. No. 220022, June 19, 2017)

—      In rape cases, the credibility of the victim is almost always the single most important issue; if the testimony of the victim passes the test of credibility, which means it is credible, natural, convincing and consistent with human nature and the normal course of things, the accused may be convicted solely on that basis; rationale; the rule finds an even more stringent application where the said findings are sustained by the CA. (People vs. Descartin, Jr., G.R. No. 215195, June 07, 2017)

—      Inconsistencies on minor details and collateral matters do not affect the substance, truth, or weight of the victim’s testimonies; minor inconsistencies may be expected of a girl of such tender years who is unaccustomed to a public trial, particularly one where she would recount such a harrowing experience as an assault to her dignity. (People vs. Entrampas, G.R. No. 212161, Mar. 29, 2017)

—      It is a well-settled rule that in the absence of palpable error or grave abuse of discretion on the part of the trial judge, the trial court’s evaluation ofthe credibility of witnesses will not be disturbed on appeal. (People vs. Alacdis, G.R. No. 220022, June 19, 2017)

—      Jurisprudence dictates that even if a witness says that what he had previously declared is false and that what he now says is true is not sufficient ground to render the previous testimony as false; rationale; application. (Guelos vs. People, G.R. No. 177000, June 19, 2017)

—      Medical findings have never been considered indispensable in supporting convictions for rape; the rape victim’s testimony, standing alone, can be made the basis of the successful prosecution of the culprit provided such testimony meets the test of credibility. (People vs. Domingo, G.R. No. 225743, June 07, 2017)

—      No mother in her right mind would subject her child to the humiliation, disgrace and trauma attendant to a prosecution for rape if she was not motivated solely by the desire to incarcerate the person responsible for her child’s defilement. (People vs. Belen, G.R. No. 215331, Jan. 23, 2017)

—      No woman, least of all a child, would concoct a story of defloration, allow examination of her private parts and subject herself to public trial or ridicule if she has not, in truth, been a victim of rape and impelled to seek justice for the wrong done to her being. (People vs. Tubillo, G.R. No. 220718, June 21, 2017)

—      Not affected by inconsistency between the witness’ affidavit and testimony on immaterial issue. (People vs. Dayaday, G.R. No. 213224, Jan. 16, 2017)

—      Not affected by minor inconsistencies in testimony. (People vs. Ambatang, G.R. No. 205855, Mar. 29, 2017)

—      Relationship by itself does not give rise to any presumption of bias or ulterior motive, nor does it impair the credibility of witnesses or tarnish their testimonies; the relationship of a witness to the victim would even make his testimony more credible, as it would be unnatural for a relative who is interested in vindicating the crime to charge and prosecute another person other than the real culprit. (People vs. Dayaday, G.R. No. 213224, Jan. 16, 2017)

 —     The evaluation of the credibility of witnesses and their testimonies is a matter best undertaken by the trial court because of its unique opportunity to observe the witnesses firsthand and to note their demeanor, conduct, and attitude under grueling examination. (Heirs of Villanueva vs. Heirs of Mendoza, G.R. No. 209132, June 05, 2017)

(People vs. Macaspac, G.R. No. 198954, Feb. 22, 2017)

(People vs. Palanay, G.R. No. 224583, Feb. 01, 2017)

—      The evaluation of the trial court judge from the viewpoint of having observed the witness on the stand, coupled by the fact that the CA affirmed the findings of the trial court, is binding on the court unless it can be shown that facts and circumstances have been overlooked or misinterpreted which, if considered, would affect the disposition of the case in a different manner. (People vs. Belen, G.R. No. 215331, Jan. 23, 2017)

—      The failure of the victim to shout during the incident would not exculpate the petitioner; whenever the credibility of any witness is in issue, the findings thereon of the trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded high respect if not conclusive effect. (Labandria Awas vs. People, G.R. No. 203114, June 28, 2017)

—      The findings of the trial court on the credibility of witnesses deserve a high degree of respect and will not be disturbed on appeal in the absence of any clear showing that the trial court overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which could have altered the conviction of the appellant. (People vs. Tuardon, G.R. No. 225644, Mar. 01, 2017)

—      The matter of assigning values to declarations on the witness stand is best and most competently performed by the trial judge, who had the unmatched opportunity to observe the witnesses and to assess their credibility by the various indicia available but not reflected on the record; when his findings have been affirmed by the CA, these are generally binding and conclusive upon this Court. (People vs. Matheus, G.R. No. 198795, June 07, 2017)

—      The police officer, who admitted that he was seven (7) to eight (8) meters away from where the actual transaction took place, could not be deemed an eyewitness to the crime. (People vs. Amin, G.R. No. 215942, Jan. 18, 2017)

—      The Supreme Court gives the highest respect to the RTC’s evaluation of the testimony of the witnesses, considering its unique position in directly observing the demeanor of a witness on the stand; from its vantage point, the trial court is in the best position to determine the truthfulness of witnesses. (People vs. Donio, G.R. No. 212815, Mar. 01, 2017)

—      The testimonies of child rape victims are generally entitled to full faith and credence as against denials and alibis, defenses which jurisprudence has long considered as weak and unreliable. (People vs. Armodia, G.R. No. 210654, June 07, 2017)

—      The testimonies of child victims especially in sensitive cases of rape, should be given credence, as no young girl would concoct a tale of defloration, allow the examination of her private parts and undergo the expense, trouble and inconvenience, not to mention the trauma and scandal of a public trial, unless she was, in fact, raped. (People vs. Belen, G.R. No. 215331, Jan. 23, 2017)

—      The trial court’s evaluation and conclusion on the credibility of witnesses in rape cases are generally accorded great weight and respect, and at times even finality, especially after the Court of Appeals as the intermediate reviewing tribunals has affirmed the findings; exception. (People vs. Domingo, G.R. No. 225743, June 07, 2017)

The trial court’s findings bearing on the credibility of witnesses on these matters are invariably binding and  conclusive  upon  the  appellate  court  unless of  course, there  is a showing  that the trial court had  overlooked, misapprehended or  misconstrued some fact or circumstance of weight or substance, or had failed to accord or assign such fact or circumstance its due import or significance. (People vs. Gabriel, G.R. No. 213390, Mar. 15, 2017)

—      The trial judge enjoys the advantage of observing the witness’ deportment and manner of testifying, all of which are useful aids for an accurate determination of a witness’ honesty and sincerity; unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected; the rule finds an even more stringent application where said findings are sustained by the CA; application. (Guelos vs. People, G.R. No. 177000, June 19, 2017)

—      There may be instances where, although a witness may not have actually seen the very act of commission of a crime, he may still be able to positively identify a suspect or accused as the perpetrator of a crime as for instance when the latter is the person or one of the persons last seen with the victim immediately before and right after the commission of the crime. (People vs. Arcenal, G.R. No. 216015, Mar. 27, 2017)

—      Upheld in the absence of ill motive. (People vs. Umapas, G.R. No. 215742, Mar. 22, 2017)

—      When inconsistencies refer only to minor details and collateral matters, they do not affect the substance or the veracity of the declarations, or the weight of the testimonies; nor do they impair the credibility of the witnesses, especially where there is consistency in the latter’s narration of the principal occurrence and positive identification of the culprit. (People vs. Arce, G.R. No. 217979, Feb. 22, 2017)

—      When it comes to the issue of credibility of the victim or the prosecution witnesses, the findings of the trial courts carry great weight and respect and, generally, the appellate courts will not overturn the said findings unless the trial court overlooked, misunderstood or misapplied some facts orcircumstances of weight and substance which will alter the assailed decision or affect the result of the case; rationale. (People vs. Tuballas, G.R. No. 218572, June 19, 2017)

(People vs. Mendoza, G.R. No. 224295, Mar. 22, 2017)

—      When it comes to the issue of credibility of witnesses, findings of the trial courts carry great weight and respect especially when affirmed by the Court of Appeals. (People vs. Pacayra, G.R. No. 216987, June 05, 2017)

—      When the issues involve matters of credibility of witnesses, the findings of the trial court, its calibration of the testimonies, and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings, are accorded high respect, if not conclusive effect. (People vs. Dayaday, G.R. No. 213224, Jan. 16, 2017)

—      When there is no evidence to show any improper motive on the part of the complainant to testify against the accused or to falsely implicate him in the commission of the crime, the logical conclusion is that the testimony is worthy of full faith and credence; the rule finds an even more stringent application where the said findings are sustained by the Court of Appeals. (People vs. Tuballas, G.R. No. 218572, June 19, 2017)

—      Witnesses are not expected to remember every single detail of an incident with perfect or total recall. (People vs. Arcenal, G.R. No. 216015, Mar. 27, 2017)

—      Witnesses cannot be expected to recollect with exactitude every minute detail of an event; this is especially true when the witnesses testify as to facts which transpired in rapid succession, attended by flurry and excitement. (Velasquez vs. People, G.R. No. 195021, Mar. 15, 2017)

Testimonies of child rape-victims —Accused’s contention that the victim merely fabricated the charge of rape and the latter’s ill motives, rejected; it has been held that it is against human nature for a young girl to fabricate a story that would expose herself as well as her family to a lifetime of shame, especially when her charge could mean the death or lifetime imprisonment of her father. (People vs. Pacayra, G.R. No. 216987, June 05, 2017)

—      Testimonies of child victims are given full weight and credit, for when a woman or a girl-child says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed. (People vs. Alberca, G.R. No. 217459, June 07, 2017)

—      Testimonies of rape victims who are young and immature deserve full credence, considering that no young woman, especially of tender age, would concoct a story of defloration, allow an examination of her private parts, and thereafter pervert herself by being subject to a public trial, if she was not motivated solely by the desire to obtain justice for the wrong committed against her. (People vs. Agudo, G.R. No. 219615, June 07, 2017)

Testimony of — Inaccuracies and inconsistencies are expected in a rape victim’s testimony; rape is a painful experience which is often times not remembered in detail; it causes deep psychological wounds that scar the victim for life and which her conscious and subconscious mind would opt to forget. (People vs. Tuballas, G.R. No. 218572, June 19, 2017)

—      Opinion of a witness is inadmissible because a witness can testify only to those facts which he knows of his own personal knowledge and it is for the court to draw conclusions from the facts testified to; opinion evidence or testimony refers to evidence of what the witness thinks, believes or infers in regard to facts in dispute, as distinguished from his personal knowledge of the facts themselves. (Belen vs. People, G.R. No. 211120, Feb. 13, 2017)

—      Testimony of the mentally-retarded rape victim, upheld; at any rate, the trial court correctly pointed out that what is significant, notwithstanding discrepancies in the victim’s testimony, was the positive identification of the accused-appellant as the person who raped or had sex with her. (People vs. Baay, G.R. No. 220143, June 07, 2017)

—      Testimony of the rape victim corroborated by the physician’s finding upheld as against bare denial of the accused. (People vs. Gacusan, G.R. No. 207776, April 26, 2017)

—      The rule is settled that when the decision hinges on the credibility of witnesses and their respective testimonies, the trial court’s observations and conclusions deserve great respect and are accorded finality, unless the records show facts or circumstances of material weight and substance that the lower court overlooked, misunderstood or misappreciated, and which, if properly considered, would alter the result of the case; rationale. (People vs. Gaa, G.R. No. 212934, June 07, 2017)

—      The Supreme Court gives the highest respect to the trial court’s evaluation of the testimony of the witnesses, considering its unique position in directly observing the demeanor of a witness on the stand. (People vs. Macaranas, G.R. No. 226846, June 21, 2017)

—      When a woman, especially a minor, alleges rape, she says in effect all that is necessary to mean that she has been raped; 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. (People vs. Tuballas, G.R. No. 218572, June 19, 2017)

Source: Supreme Court of the Philippines