PEOPLE OF THE PHIL v. RODOLFO VILLADARES G.R. No. 137649 March 8, 2001
April 11, 2011
PEOPLE OF THE PHIL v. RODOLFO VILLADARES
G.R. No. 137649 March 8, 2001
Accused was found guilty of raping a 12-yr old girl, and was sentenced to suffer the penalty of reclusion perpetua.
Accused assails the credibility of the witness and the supposed inconsistencies in the testimonies. The SC still affirmed the ruling of the lower court.
First. It is doctrinal that the evaluation by the trial court of the testimony of a witness is accorded with highest respect because the trial court had the direct and singular opportunity to observe the facial expression, gesture and tone of voice of a witness while testifying and therefore, competent to determine whether or not the witness is telling the truth.
Second. The alleged inconsistency between the testimony of Eliza (victim) and Emma, that is, that the latter testified that Eliza shouted, is trivial and cannot affect the veracity of their testimonies. Inconsistencies in the testimonies of witnesses which refer to minor and insignificant details do not destroy their credibility. Such minor inconsistencies even manifest truthfulness and candor and erase any suspicion of rehearsed testimony.
Third. The inconsistencies in Emma’s statement before the police authorities and her testimony in open court cannot detract from Eliza’s testimony that she was raped on July 20, 1996 by accused-appellant. Discrepancies and/or inconsistencies between a witness’ affidavit and testimony in open court do not impair credibility as affidavits are taken ex parte and are often incomplete or inaccurate for lack of or absence of searching inquiries by the investigating officer. In any event, we find that Emma’s testimony in court sufficiently corroborates that of Eliza on material points.
Lastly, with or without the medical certificate, the testimony of Eliza, as corroborated by her sister Emma is sufficient to convict. This Court has ruled that a medical examination of the victim is not indispensable in a prosecution for rape; and that a victim’s testimony alone if credible is sufficient to convict the appellant of the crime.
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