WITNESSES

Credibility of a Mentally Retarded Witness

People of the Philippines v. Ninoy Rosales y Esto
G.R. No.197537
July 24, 2013
Doctrine:
A deaf-mute may not be able to hear and speak but his/her other senses, such as his/her
sense of sight, remain functional and allow him/her to make observations about his/her
environment and experiences; Thus, a deaf-mute is competent to be a witness so long as
he/she has the faculty to make observations and he/she can make those observations
known to others.

RAPE CASES
Conviction based on Sole Testimony of Victim
People of the Philippines v. Edmundo Vitero
G.R. No. 175327
April 3, 2013
Doctrine:
In a prosecution for rape, the accused may be convicted solely on the basis of the testimony
of the victim that is credible, convincing, and consistent with human nature and the normal
course of things, as in this case.
The Supreme Court held that different people react differently to different situations and
there is no standard form of human behavioral response when one is confronted with a
frightful experience. While the reaction of some women, when faced with the possibility of
rape, is to struggle or shout for help, still others become virtually catatonic because of the
mental shock they experience. In the instant case, it is not inconceivable or improbable that
[private complainant], being of tender age, would be intimidated into silence by the threats
and actions of her father.

PHYSICIAN-PATIENT PRIVILEGED COMMUNICATION

Josielene Lara Chan v. Johnny T. Chan
G.R. No. 179786
July 24, 2013
Doctrine:
Physician-patient privileged communication rule essentially means that a physician who
gets information while professionally attending a patient cannot in a civil case be examined
without the patients consent as to any facts which would blacken the latters
reputation. The time to object to the admission of evidence would be at the time they are

offered. The offer could be made part of the physicians testimony or as independent
evidence that he had made entries in those records that concern the patients health
problems. To allow, however, the disclosure during discovery procedure of the hospital
recordsthe results of tests that the physician ordered, the diagnosis of the patients
illness, and the advice or treatment he gave himwould be to allow access to evidence
that is inadmissible without the patients consent.

RAPE CASES
Conviction based on Sole Testimony of Victim
People of the Philippines v. Edmundo Vitero
G.R. No. 175327
April 3, 2013
Doctrine:
In a prosecution for rape, the accused may be convicted solely on the basis of the testimony
of the victim that is credible, convincing, and consistent with human nature and the normal
course of things, as in this case.
The Supreme Court held that different people react differently to different situations and
there is no standard form of human behavioral response when one is confronted with a
frightful experience. While the reaction of some women, when faced with the possibility of
rape, is to struggle or shout for help, still others become virtually catatonic because of the
mental shock they experience. In the instant case, it is not inconceivable or improbable that
[private complainant], being of tender age, would be intimidated into silence by the threats
and actions of her father.

SUBSTANTIAL EVIDENCE
Office of the Ombudsman v. Arnel A. Bernardo
G.R. No. 181598
March 6, 2013
Doctrine:
Administrative proceedings are governed by the substantial evidence rule. Otherwise
stated, a finding of guilt in an administrative case would have to be sustained for as long as
it is supported by substantial evidence that the respondent has committed acts stated in the
complaint. Substantial evidence is more than a mere scintilla of evidence. It means such
relevant evidence as a reasonable mind might accept as adequate to support a conclusion,
even if other minds equally reasonable might conceivably opine otherwise.

SUMMARY OF DOCTRINES ON RULES OF EVIDENCE

Submitted by:

Emelita C. Basan

Submitted to:

Judge Francisco V.L. Collado, Jr.