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PEOPLE OF THE PHILIPPINES VS. FLORANTE RELANES G.R. NO.

175831

FACTS: Private complainant AAA was only eight years old when her father, the accused herein raped her on the first week of Aug. 2002 and on Jan. 9, 2003. The victim got pregnant as a result of the abuses where the accused threatened to kill her and her family if she would tell anyone. AAA gave a testimony and described how she was abused. Accused denied the rape incident on Jan. 2003 but eventually admitted on having sexual intercourse with AAA on Aug. 2002. During the course of the trial, he pleaded forgiveness to his wife, daughter and other members of his family. He was convicted for each count of rape with a penalty of death. Judgment was affirmed by CA hence, the automatic review. ISSUES: 1. Whether or not the trial court erred gravely in giving full weight and credence to the incredible statement of AAA; 2. Whether or not the plea for forgiveness by the accused can be considered as an attempt to compromise and is therefore admissible in evidence as an admission of guilt; RULINGS: 1. NO. The defense of the accused of denial and alibi should be dismissed outright in light of his positive identification of AAA. It is an established rule that denial and alibi, being negative selfserving defences, cannot prevail over the positive allegations of the victim and her categorical and positive identification of the accused as her assailant. 2. YES. Evidently, no one would ask for forgiveness unless he committed some wrong and a plea for forgiveness may be considered as analogous to an attempt to compromise. Settled is the rule that in criminal cases, except those involving quasi-offenses as those allowed by law to be settled through mutual concessions, an offer to compromise by the accused may be received in evidence as an implied admission of guilt. Under the circumstances, his plea for forgiveness should be received as an implied admission of guilt. Judgment of CA was affirmed. Penalty of death reduced to reclusion perpetua.

PP VS. GILBERTO VILLARICO SR., ET AL G.R. NO. 158362

FACTS: On Aug. 8, 1999, Haide was in their kitchen at their home in Misamis Occ. Remedios, Haides sister-in-law, saw all the accused standing at the rear of the kitchen, aiming their firearms to the door. Gilberto Jr, one of the accused, saw Remedios and then aimed his gun at her causing her to shout to help. Three gunshots were heard. Francisco heard the gunshots causing him to look into a hole where he saw all of the accused by the kitchen door w/ their guns held upward. They all left w/ co-accused Ramentos. Haide who died later because of the gunshot wounds was able to tell Lolita that he was shot by Berting. All of the accused interposed their alibis and claimed that the prosecution witnesses did not actually see who shot Haide. Hence, their identification as killers was not positively made. Accused were found guilty with homicide aggravated by dwelling but were found guilty of murder on appeal because of the presence of treachery. Hence, the appeal. ISSUE Should an identification to be positive, have to be made by a witness who actually saw the assailants? RULING: No. Positive identification pertains essentially to proof of identity and not per se to the act of being an eyewitness to the commission of the crime. Although a witness may not have actually seen the very act of a crime, he may still be able to positively identify the suspect, such as where the suspect is last seen with the victim immediately before or after the crime was committed. This type of positive identification which forms part of circumstantial evidence, which when taken together with other pieces form part of an unbroken chain, leads to a reasonable conclusion that the accused is the author of the crime to the exclusion of all others. Trustworthy circumstantial evidence can equally confirm the identification and overcome the presumed innocence of the accused. Judgment of Ca was affirmed. Penalty of reclusion perpetua was imposed.

PEOPLE OF THE PHILIPPINES VS. RONALDO SALUDO G.R. NO. 178406 FACTS: On April 10, 1995, AAA was only 14 years when she was raped while her mother was away. The accused entered their hut while AAA was sleeping. He poked a knife at her and eventually raped her. He also threatened to kill her and her family if she would tell anyone.

AAA said the rape incidents for three (3) times more. She got pregnant and she informed her mother of what the accused did. They reported the incident to the police station and AAA positively identified the accused in open court. The accused who was a neighbour of the victim, denied the accusation to the alleged rape incidents. As his alibi, he said that he was in a political rally and proceeded to the pabasa on April 10, 1995.

Accused was convicted of four (4) counts of rape in the trial court with a penalty of reclusion perpetua. CA affirmed the decision hence, the appeal.

ISSUE: Whether or not the trial court erred in not rejecting the highly preposterous, if not obviously rehearsed testimony of AAA? RULING: NO. Accused merely raised denial and alibi as his defences. Fundamental is the rule that alibi is the weakest of all defenses., because it is easy to concoct an difficult to disprove. Private complainant in open court, positively identified the accused as the assailant in four rape incidents. Such a categorical and positively identification of an accused, without any showing of ill-motive on the motive on the part of the witness testifying on the matter, prevails over the alibi and denial of the accused which are negative and self-serving evidence undeserving of real weight in law. Judgment of CA was affirmed.