Pasion vs.

Melegrito
RATIO: The principle of equitable estoppel would now operate
to prevent petitioner from asserting her alleged ownership over
the structure and defeating the alias writ of execution issued in
execution of the decision in the Civil Case. 2(a), Rule 131 of
the Rules of Court states: Whenever a party has, by his own
declaration, act, or omission, intentionally and deliberately led
another to believe a particular thing true, and to act upon such
belief, he cannot, in any litigation arising out of such
declaration, act or omission, be permitted to falsify it.
Thus, we have held: The principles of equitable estoppel,
sometimes called estoppel in pais, are made part of our law by
Art. 1432 of the Civil Code. Coming under this class is
estoppel by silence, which obtains here and as to which it has
been held that: x x x an estoppel may arise from silence as
well as from words. Estoppel by silence arises where a
person, who by force of circumstances is under a duty to
another to speak, refrains from doing so and thereby
leads the other to believe in the existence of a state of
facts in reliance on which he acts to his prejudice. Silence
may support an estoppel whether the failure to speak is
intentional or negligent.
Phil. Savings Bank vs. Chowking Food Corp.
RATIO: The doctrine of equitable estoppel or estoppel in pais
finds no application in the present case. The equitable doctrine
of estoppel was explained by this Court in Caltex, Inc. v. CA,
(1992): Under the doctrine of estoppel, an admission or
representation is rendered conclusive upon the person
making it, and cannot be denied or disproved as against
the person relying thereon. A party may not go back on his
own acts and representations to the prejudice of the other
party who relied upon them. In the law of evidence, whenever

a party has, by his own declaration, act, or omission,

intentionally and deliberately led another to believe a particular
thing true, to act upon such belief, he cannot, in any litigation
arising out of such declaration, act, or omission, be permitted
to falsify it.
Kalalo vs. Luz
RATIO: Under Article 1431 of the Civil Code, in order that
estoppel may apply the person, to whom representations
have been made and who claims the estoppel in his favor,
must have relied or acted on such representations.
The essential elements of estoppel in pais in relation to the
party sought to be estopped are: (1) conduct amounting to
false representation or concealment of material facts; or
at least calculated to convey the impression that the facts
are otherwise than, and inconsistent with, those which the
party subsequently attempts to assert; (2) intent, or at
least expectation that this conduct shall be acted upon by,
or at least influence, the other party; and (3) knowledge,
actual or constructive, of the real facts.
As related to the party claiming the estoppel, the essential
elements are (1) lack of knowledge and of the means of
knowledge of the truth as to the facts in question; (2) reliance,
in good faith, upon the conduct or statements of the party to be
estopped; (3) action or inaction based thereon of such
character as to change the position or status of the party
claiming the estoppel, to his injury, detriment or prejudice.
If an act, conduct, or misrepresentation of the party sought
to be estopped is due to ignorance founded on innocent
mistake, estoppel will not arise.

When a party to a suit has made an admission of any fact

pertinent to the issue involved, the admission can be received
against him; but such an admission is not conclusive against
him, and he is entitled to present evidence to overcome the
effect of the admission. An admission based on either
ignorance or innocent mistake may overcome the effect of the
admission.
How impeached: An account stated or settled is a mere
admission that the account is correct. It is not an
estoppel. The account is still open to impeachment for
mistakes or errors. Its effect is to establish, prima facie, the
accuracy of the items without other proof; and the party
seeking to impeach it is bound to show affirmatively the
mistake or error alleged. The force of the admission and the
strength of the evidence necessary to overcome it will depend
upon the circumstances of the case.
People vs. Jubilag
RATIO: As in every case, there are two sides to this one, the
prosecutions and the appellants. Who to believe is a matter of
credibility, and is usually best ascertained by the trial court
which had the opportunity to observe the witnesses directly
and to test their credibility by their demeanor on the stand.
Thus, the general rule that factual findings of the trial court are
accorded respect and are not disturbed on appeal. But a
review of the records of the instant case compels us to take
exception to the aforementioned general rule. At the outset, it
is important to note that the judge who decided this case was
not the same one who heard the evidence. And the rule that
findings of the trial court on the credibility of witnesses are
accorded great weight does not apply when the judge who
rendered the decision was not the judge who heard the
witnesses. More importantly, we find that the trial court erred in

adopting the prosecutions story hook, line and sinker albeit

riddled with patent inconsistencies and improbabilities on
material points.
We are baffled by the glaring inconsistencies between the
testimonies of these two key eyewitnesses. As their
testimonies cannot stand together, the inevitable conclusion is
that one or both must be telling a lie, and as correctly averred
by the appellant, their story is a mere concoction.
The credibility of the prosecution witnesses is highly
questionable and crumbles in the face of the aforementioned
inconsistencies in their testimonies and the suspicious
circumstances surrounding appellants arrest. How the trial
court could have overlooked these continues to puzzle us. In
upholding the prosecution, the trial court erroneously relied,
first, on the general rule that inconsistencies in the testimonies
of prosecution witnesses with respect to minor details and
collateral matters do not affect either the substance of their
declaration, their veracity, or the weight of their testimony, and
second, on the presumption of regularity in the performance of
official duties by the police officers. However entrenched these
rules may be, they do not find application in the case at bar.
Thus, in People v. Remorosa, where the testimony of the
police officer was tainted with material contradictions, we held
that, irreconcilable and unexplained contradictions in the
testimonies of the prosecution witnesses cast doubt on the
guilt of the appellant and his culpability of the crime charged.
As in the said case, the moral certainty of the appellants
culpability has not been established in this case. Instead, the
palpable inconsistencies on material points corroborate
and strengthen appellants version of the incident.

Dutch Boy vs. Seniel

RATIO: It is a basic rule in civil cases that the party having the
burden of proof must establish his case by preponderance of
evidence. Preponderance of evidence is the weight, credit,
and value of the aggregate evidence on either side and is
usually considered to be synonymous with the term
greater weight of the evidence or greater weight of the
credible evidence. It is evidence which is more convincing to
the court as worthy of belief than that which is offered in
opposition thereto. Although the evidence adduced by plaintiff
is stronger than that presented by defendant, a judgment
cannot be entered in favor of the former, if his evidence is
not sufficient to sustain his cause of action.
Ching Sui Yong vs. IAC
RATIO: In short, the failure of petitioner to produce the person
to whom he allegedly paid P75, 000.00 for the seven (7) films,
rendered his claim untenable. For, when a party has it in his
possession or power to produce the best evidence of which
the case in its nature is susceptible and withholds it, the fair
presumption is that the evidence is withheld for some
sinister motive and that its production would thwart his
evil or fraudulent purpose.
People vs. De Jesus
RATIO: It is evident, therefore, that the resolution of this case
hinges on the issue of credibility. On this score, it is a wellsettled rule in our jurisdiction that the findings of the trial court
regarding the issue of credibility of witnesses and their
testimonies are entitled to great respect and are accorded
the highest consideration by appellate courts. Deviation
from the rule is allowed only when the circumstances of the
case show that the trial court has overlooked facts which will
substantially alter the results of its adjudication. Corollary to

this, it has likewise been consistently ruled that credibility is a

matter that is peculiarly within the province of the trial judge,
who had first-hand opportunity to watch and observe the
demeanor and behavior of witnesses, both for the prosecution
and the defense, at the time of their testimony.
This Court has repeatedly ruled that the prosecution may
decide on who should be presented as witnesses. Moreover,
the adverse presumption from suppression of evidence is
not applicable when (1) the suppression is not wilful; (2)
the evidence suppressed or withheld is merely
corroborative or cumulative; (3) the evidence is at the
disposal of both parties; and (4) the suppression is an
exercise of a privilege. In this case, the failure of the
prosecution to present the confidential informant was not
wilfully unjustified. As the Solicitor General puts it, police
informants work incognito; to parade them in court would
destroy their usefulness. Therefore, his identity may remain
confidential. There are strong practical reasons for such
continued secrecy, including the continued health and safety
of the informer and the encouragement of others to report
wrongdoings to the police authorities.
Finally, the defense of appellant constitutes a combination of
an alibi and denial, definitely the weakest defense. Trite as
it may appear to be, we repeat all over that to serve as a basis
for acquittal, the defense of alibi must be established by
clear and convincing evidence. The requisites of time and
place must be strictly met. It must affirmatively appear not only
that the accused was at some other place at the time of the
perpetration of the offense but also that the circumstances are
such as logically to generate the conclusion that it was
physically impossible for him to be present at the scene of the
crime at the time of its commission.

People vs. Boduso

RATIO: We find no error in the trial court's refusal to accord
credence to the version of the appellant. The attitude of utter
indifference shown by appellant in connection with the alleged
attack by Danton Anisco is so unnatural. He was not even
curious to know why Anisco stabbed the two victims. In spite
of the fact that he was already charged with the commission of
the offense, he never bothered to inform the Fiscal when he
was investigated that he was innocent as the assailant was in
reality Danton Anisco. Apart from the foregoing, his utter lack
of concern during the trial, as he was even chided by the trial
judge for laughing while Rolando Regalado was testifying, is
evidentiary of his lack of sincerity.

There is no question that the testimony of a single
witness, when it is reasonable and credible, is sufficient to
convict. Corroborative evidence is necessary when there are
reasons to suspect that the witness falsified the truth, or there
exist inherent incongruities in his testimony, or there is
probability that his observation has been inaccurate. We find
no fact or circumstance that would detract from the credibility
of Regalado's testimony.
People vs. Asis
RATIO: Certainly, it is not only by direct evidence that the
accused may be convicted of the crime charged.
Circumstantial evidence is resorted to when direct
testimony would result in setting felons free and deny
proper protection to the community. The former is not a
weaker form of evidence vis--vis the latter. The accused
may be convicted on the basis of circumstantial evidence,
provided the proven circumstances constitute an
unbroken chain leading to one fair reasonable conclusion
pointing to the accused, to the exclusion of all others, as

the guilty person. Circumstantial evidence is akin to a

tapestry; it should be made up of strands which create a
pattern when interwoven. This pattern should be reasonably
consistent with the hypothesis that the accused is guilty and at
the same time totally inconsistent with the proposition that he
or she is innocent.
It escapes this Court how the recovery of a bloodstained pair
of shorts allegedly owned by the victim should give rise to the
presumption that one of the appellants was the taker and doer
of the whole act of robbery with homicide. By itself, the
retrieval of the pair of shorts does not prove that appellants, or
even just one of them, robbed the trouser owner of cash and
jewelry and also killed him, as charged in the Information.
Neither does it show that appellants, or one of them,
perpetrated the aggression leading to the victims death.
Again, this fact cannot be taken as an indication of guilt on the
part of Appellant Asis. It does not point to the conclusion that
he was involved in the crime charged against him. We cannot
agree that since there was bloodstain on his clothing, ergo, he
committed the robbery and the attendant killing. At most, this
piece of circumstantial evidence, taken with the other one,
may lead to suspicion. But courts do not rely on
circumstantial evidence that merely arouses suspicion or
conjecture. For circumstantial evidence to lead to conviction,
it must do more than just raise the mere possibility or even
probability of guilt. It must engender moral certainty.