Fatima Kate N.

Garo
LL.B. I

4. Jurisprudence for the Credibility of the Testimony of a Victim in Rape Cases

In deciding rape cases, Courts are guided by these three well-entrenched principles: (a) an accusation for
rape can be made with facility, it is difficult to prove but more difficult for the person accused, though
innocent, to disprove; (b) in view of the intrinsic nature of the crime, where only two persons are usually
involved, the testimony of the complainant must be scrutinized with utmost caution; and (c) the evidence
of the prosecution must stand on its own merits and cannot draw strength from the weakness of the evidence
for the defense. (People v. Marcos, G.R. No. 185380, June 18, 2009, 589 SCRA 661, 669) As a result of
these guiding principles, the credibility of the victim becomes the single most important issue (Ibid.)

The presumption in rape cases is that the complainant is telling the truth because she would otherwise not
submit herself to the embarrassment of a public trial where the sordid details of her violation will be exposed
and every intimate part of her body will be examined. On the other hand, there is also the presumption of
innocence, to be observed in every criminal prosecution, where the accused must be considered not guilty
of the offense charged until the contrary is proved. (People v Sandagon, G.R. No. 106897, June 13, 1994)

In rape, the controversy usually boils down to the credibility of the victim’s testimony. The trial courts
evaluation of the credibility of the victim’s statements is accorded great weight because it has the unique
opportunity of hearing the witnesses testify and observing their deportment and manner of testifying. The
trial court judge is no doubt in the best position to determine the truthfulness of the complainant’s
testimony. Thus, unless it is shown that the trial court overlooked, misunderstood or misapplied some facts
or circumstances of weight or substance that would otherwise affect the result of the case, its findings will
not be disturbed on appeal. (People v. Rebato, 358 SCRA 230, 236 (2001))

It was also that for evidence to be believed, however, it must not only proceed from the mouth of a credible
witness but must be credible in itself such as the common experience and observation of mankind can
approve under the circumstances. The test to determine the value of the testimony of a witness is whether
such is in conformity with knowledge and consistent with the experience of mankind. Whatever is
repugnant to these standards becomes incredible and lies outside of judicial cognizance. (People v.
Laurente, 353 SCRA 765, 777 (2001))

By the very nature of the crime of rape, the lone testimony of the complainant is enough to sustain a
conviction, provided that such testimony must meet the test of credibility, which means, that the testimony
should not only come from the mouth of a credible witness, it should likewise be credible and reasonable
in itself, candid, straightforward and in accord with human experience. (People vs. Torion, 307 SCRA 169,
175-176 (1999)).Hence, the exacting standard of proof beyond reasonable doubt acquires more relevance
in rape charges which are easy to make but harder to prove and harder still to defend by the party accused
who may be innocent. (People v. Mariano, 345 SCRA 1, 10 (2000))

In other words, the complainant’s testimony if credible, natural, convincing, and consistent with human
nature and the normal course of things may suffice to support a conviction of rape. (People v. Nazareno,
G.R. No. 167756, April 9, 2008, 551 SCRA 16, 31)

On the other hand, defendant can be merited with an acquittal, even if his own evidence is not as persuasive
as would otherwise be desired. (People v Sandagon G.R. No. 106897 June 13, 1994). Although denial and
alibi are generally held to be weak and unavailing, these defenses gain commensurate strength when the
credibility of the prosecution witnesses is wanting and questionable. (Bartocillo v. Court of Appeals, G.R.
No. 125193, Oct. 23, 2001) The prosecution cannot rely on the weakness of the evidence for the defense
but must depend on the strength of its own evidence to prove the guilt of the accused. If prosecution
evidence is insufficient to overcome the presumption of innocence accorded by the Constitution to an
accused, then the latter should be acquitted. (People v Padilla, G.R. No. 145460. July 3, 2002)