Scribd Logo
Upload

Welcome to Scribd!

  • Delay Filing of Rape Case

    Uploaded by

    Jurisprudence Law
    16 views2 pages
    Delay in reporting a rape does not necessarily undermine a victim's credibility, as the court has consistently held. While the appellant argued that the private complainant's four-year delay in reporting the alleged crimes cast doubt on her motive and credibility, the court disagreed. It noted that it is best to defer to the trial court's assessment of witness credibility and testimony, having directly observed the witnesses. The court also noted that delay in reporting rape is not uncommon, as rape victims may be traumatized or threatened into silence, so delay alone does not indicate a false accusation. However, any delay must still be adequately explained.

    Original Description:

    jurisprudence for delayed filing of rape case

    Original Title

    Delay filing of rape case

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    Delay in reporting a rape does not necessarily undermine a victim's credibility, as the court has consistently held. While the appellant argued that the private complainant's four-year delay in reporting the alleged crimes cast doubt on her motive and credibility, the court disagreed. It noted that it is best to defer to the trial court's assessment of witness credibility and testimony, having directly observed the witnesses. The court also noted that delay in reporting rape is not uncommon, as rape victims may be traumatized or threatened into silence, so delay alone does not indicate a false accusation. However, any delay must still be adequately explained.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    16 views2 pages

    Delay Filing of Rape Case

    Uploaded by

    Jurisprudence Law
    Delay in reporting a rape does not necessarily undermine a victim's credibility, as the court has consistently held. While the appellant argued that the private complainant's four-year delay in reporting the alleged crimes cast doubt on her motive and credibility, the court disagreed. It noted that it is best to defer to the trial court's assessment of witness credibility and testimony, having directly observed the witnesses. The court also noted that delay in reporting rape is not uncommon, as rape victims may be traumatized or threatened into silence, so delay alone does not indicate a false accusation. However, any delay must still be adequately explained.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    of 2

    G.R. Nos.

    135454-56 November 13, 2001

    PEOPLE OF THE PHILIPPINES, appellee,


    vs.
    RODERICK SANTOS y YAMAT, appellant.

    PANGANIBAN, J.:

    Delay in reporting a rape does not necessarily taint the victim's testimony, provided it is satisfactorily
    explained, as in this case.

    Appellant faults private complainant for her unreasonable and unjustified delay in reporting the
    alleged crimes. He casts serious doubts on her true motive by pointing out that she filed 14 the three
    charges more than four years after the first rape had supposedly taken place. He likewise questions
    her credibility by citing material inconsistencies in her testimony.
    14
    The cases were filed on October 23, 1997.

    We disagree. We have consistently held that the assessment of the credibility of witnesses and their
    testimonies is best left to the trial court because of its unique opportunity to observe them firsthand
    and to note their demeanors and attitudes on the witness stand. Hence, its findings are accorded
    great weight and deemed binding and conclusive on appellate courts, unless some facts or
    circumstances of weight and substance have been overlooked or misinterpreted. 15
    15
    People v. Raul Tagaba and Jaime Tolibas, GR Nos. 112792-93, October 6, 2000, per Quisumbing,
    J.

    delay in reporting a crime of rape has not always been construed as an indication of a false
    accusation.16 In fact, this Court has repeatedly held that it is not uncommon for young girls to conceal
    for some time the assault on their virtue because of the rapist's threat on their lives. x x x [R]ape is a
    traumatic event, and the shock concomitant with it may linger for a while. 17

    16
    People v. Alimon, 257 SCRA 658, June 28, 1996.

    17
    People v. Malabago, 271 SCRA 464, April 18, 1997.

    G.R. No. 146327-29 June 5, 2002

    PEOPLE OF THE PHILIPPINES, appellee,


    vs.
    ERNIE BARO, appellant.

    PANGANIBAN, J.:

    In rape, the complainant's delayed disclosure of the crime to kith or kin or persons of authority does
    not always warrant the conclusion that the woman was not sexually molested or that her charges
    against the accused are baseless and fabricated.17 However, the delay must be adequately and
    satisfactorily explained; otherwise, it would generate doubt as to the guilt of the accused. 18

    17
    People v. Garcia et. al., 105 SCRA 6, June 11, 1981.

    18
    People v. Cueto, 84 SCRA 774, August 25, 1978.

    You might also like