PEOPLE vs. PAREJA

RULE 120
46. PEOPLE vs. PAREJA
G.R. No. 202122 January 15, 2014
FACTS: AAA was thirteen (13) years of age when the alleged acts of
lasciviousness and sexual abuse took place on three (3) different dates.
AAA’s parents separated when she was only eight years old. At the time of
the commission of the aforementioned crimes, AAA was living with her mother
and with herein accused-appellant Bernabe Pareja who, by then, was
cohabiting with her mother, together with three (3) of their children, aged
twelve (12), eleven (11) and nine (9), in x x x, Pasay City.
The first incident took place in December 2003 [the December 2003 incident].
AAA’s mother was not in the house and was with her relatives in Laguna.
Taking advantage of the situation, Pareja, while AAA was asleep, placed
himself on top of her. Then, Pareja, who was already naked, begun to undress
AAA. Pareja then started to suck the breasts of AAA. Not satisfied, Pareja
likewise inserted his penis into AAA’s anus. Because of the excruciating pain
that she felt, AAA immediately stood up and rushed outside of their house.
Despite such traumatic experience, AAA never told anyone about the
[December 2003] incident for fear that Pareja might kill her. [Pareja]
threatened to kill AAA in the event that she would expose the incident to
anyone.
AAA further narrated that the [December 2003] incident had happened more
than once. According to AAA, in February 2004 [the February 2004 incident],
she had again been molested by Pareja. Under the same circumstances as
the December 2003 incident], with her mother not around while she and her
half-siblings were asleep, Pareja again laid on top of her and started to suck
her breasts. But this time, Pareja caressed her and held her vagina and
inserted his finger in it.
With regard to the last incident, on March 27, 2004 [the March 2004 incident],
it was AAA’s mother who saw Pareja in the act of lifting the skirt of her
daughter AAA while the latter was asleep. Outraged, AAA’s mother
immediately brought AAA to the barangay officers to report the said incident.
AAA then narrated to the barangay officials that she had been sexually
abused by Pareja x x x many times x x x.
On May 5, 2004, Pareja was charged with two counts of Rape and one
Attempted Rape.
RTC: Acquitted Pareja from the charge of attempted rape but convicted him
of the crimes of rape and acts of lasciviousness in the December 2003 and
February 2004 incidents, respectively.

CA: DENIED.
ISSUE: Whether the trial court seriously erred in convicting Pareja of the
crimes charged on the ground that AAA’s testimony cannot be the lone basis
of his conviction as it was riddled with inconsistencies.
RULING: No. When the issue of credibility of witnesses is presented before
this Court, we follow certain guidelines that have overtime been established
in jurisprudence. In People v. Sanchez, we enumerated them as follows:
First, the Court gives the highest respect to the RTC’s evaluation of the
testimony of the witnesses, considering its unique position in directly
observing the demeanor of a witness on the stand. From its vantage point,
the trial court is in the best position to determine the truthfulness of witnesses.
Second, absent any substantial reason which would justify the reversal of the
RTC’s assessments and conclusions, the reviewing court is generally bound
by the lower court’s findings, particularly when no significant facts and
circumstances, affecting the outcome of the case, are shown to have been overlooked or disregarded. And
third, the rule is even more stringently applied if the CA concurred with the RTC. The recognized rule in this
jurisdiction is that the "assessment of the credibility of witnesses is a domain best left to the trial court judge
because of his unique opportunity to observe their deportment and demeanor on the witness stand; a vantage
point denied appellate courts-and when his findings have been affirmed by the Court of Appeals, these are
generally binding and conclusive upon this Court." While there are recognized exceptions to the rule, this Court
has found no substantial reason to overturn the identical conclusions of the trial and appellate courts on the
matter of AAA’s credibility. Besides, inaccuracies and inconsistencies in a rape victim’s testimony are generally
expected. As this Court stated in People v. Saludo: Rape is a painful experience which is oftentimes not
remembered in detail. For such an offense is not analogous to a person’s achievement or accomplishment as
to be worth recalling or reliving; rather, it is something which causes deep psychological wounds and casts a
stigma upon the victim, scarring her psyche for life and which her conscious and subconscious mind would opt
to forget. Thus, a rape victim cannot be expected to mechanically keep and then give an accurate account of
the traumatic and horrifying experience she had undergone. As regards Pareja’s concern about AAA’s lone
testimony being the basis of his conviction, this Court has held: Furthermore, settled is the rule that the
testimony of a single witness may be sufficient to produce a conviction, if the same appears to be trustworthy
and reliable. If credible and convincing, that alone would be sufficient to convict the accused.

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RULE 120

46. PEOPLE vs. PAREJA

G.R. No. 202122 January 15, 2014

and with herein accused-appellant Bernabe Pareja who, by then, was

twelve (12), eleven (11) and nine (9), in x x x, Pasay City.

inserted his finger in it.

abused by Pareja x x x many times x x x.

February 2004 incidents, respectively.

of his conviction as it was riddled with inconsistencies.

RULING: No. When the issue of credibility of witnesses is presented before

in jurisprudence. In People v. Sanchez, we enumerated them as follows:

testimony of the witnesses, considering its unique position in directly

RTC’s assessments and conclusions, the reviewing court is generally bound

by the lower court’s findings, particularly when no significant facts and

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