Evidence Case Digest

PEOPLE OF THE PHILIPPINES VS.
FLORANTE RELANES
G.R. NO. 175831
FACTS:
Private complainant was only eight years old when her father, the accused herein raped her on
the first week of Aug. 2002 and on Jan. 9, 2003. The victim got pregnant as a result of the abuses
where the accused threatened to kill her and her family if she would tell anyone. The victim gave
a testimony and described how she was abused.
Accused denied the rape incident on Jan. 2003 but eventually admitted on having sexual
intercourse with the said victim on Aug. 2002. During the course of the trial, he pleaded
forgiveness to his wife, daughter and other members of his family. He was convicted for each
count of rape with a penalty of death. Judgment was affirmed by CA hence, the automatic
review.
ISSUES:
1. Whether or not the trial court erred gravely in giving full weight and credence to the incredible
statement of the victim;
2. Whether or not the plea for forgiveness by the accused can be considered as an attempt to
compromise and is therefore admissible in evidence as an admission of guilt;
RULINGS:
1. NO. The defense of the accused of denial and alibi should be dismissed outright in light of his
positive identification of the victim. It is an established rule that denial and alibi, being negative
self-serving defences, cannot prevail over the positive allegations of the victim and her
categorical and positive identification of the accused as her assailant.
2. YES. Evidently, no one would ask for forgiveness unless he committed some wrong and a
plea for forgiveness may be considered as analogous to an attempt to compromise. Settled is the
rule that in criminal cases, except those involving quasi-offenses as those allowed by law to be
settled through mutual concessions, an offer to compromise by the accused may be received in
evidence as an implied admission of guilt. Under the circumstances, his plea for forgiveness
should be received as an implied admission of guilt.
Judgment of CA was affirmed. Penalty of death reduced to reclusion perpetua.

PP VS. GILBERTO VILLARICO SR., ET AL
G.R. NO. 158362
FACTS:
On Aug. 8, 1999, Haide was in their kitchen at their home in Misamis Occ. Remedios, Haide’s
sister-in-law, saw all the accused standing at the rear of the kitchen, aiming their firearms to the
door. Gilberto Jr, one of the accused, saw Remedios and then aimed his gun at her causing her to
shout to help. Three gunshots were heard. Francisco heard the gunshots causing him to look into
a hole where he saw all of the accused by the kitchen door w/ their guns held upward. They all
left w/ co-accused Ramentos.
Haide who died later because of the gunshot wounds was able to tell Lolita that he was shot by
Berting. All of the accused interposed their alibis and claimed that the prosecution witnesses did
not actually see who shot Haide. Hence, their identification as killers was not positively made.
Accused were found guilty with homicide aggravated by dwelling but were found guilty of
murder on appeal because of the presence of treachery. Hence, the appeal.
ISSUE
Should an identification to be positive, have to be made by a witness who actually saw the
assailants?
RULING:
No. Positive identification pertains essentially to proof of identity and not per se to the act of
being an eyewitness to the commission of the crime. Although a witness may not have actually
seen the very act of a crime, he may still be able to positively identify the suspect, such as where
the suspect is last seen with the victim immediately before or after the crime was committed.
This type of positive identification which forms part of circumstantial evidence, which when
taken together with other pieces form part of an unbroken chain, leads to a reasonable conclusion
that the accused is the author of the crime to the exclusion of all others. Trustworthy
circumstantial evidence can equally confirm the identification and overcome the presumed
innocence of the accused.
Judgment of Ca was affirmed. Penalty of reclusion perpetua was imposed.

PEOPLE OF THE PHILIPPINES VS. RONALDO SALUDO
G.R. NO. 178406
FACTS:
On April 10, 1995, AAA was only 14 years when she was raped while her mother was away.
The accused entered their hut while AAA was sleeping. He poked a knife at her and eventually
raped her. He also threatened to kill her and her family if she would tell anyone.
AAA said the rape incidents for three (3) times more. She got pregnant and she informed her
mother of what the accused did. They reported the incident to the police station and AAA
positively identified the accused in open court. The accused who was a neighbour of the victim,
denied the accusation to the alleged rape incidents. As his alibi, he said that he was in a political
rally and proceeded to the pabasa on April 10, 1995.
Accused was convicted of four (4) counts of rape in the trial court with a penalty of reclusion
perpetua. CA affirmed the decision hence, the appeal.
ISSUE: Whether or not the trial court erred in not rejecting the highly preposterous, if not
obviously rehearsed testimony of AAA?
RULING:
NO. Accused merely raised denial and alibi as his defences. Fundamental is the rule that alibi is
the weakest of all defenses., because it is easy to concoct an difficult to disprove. Private
complainant in open court, positively identified the accused as the assailant in four rape
incidents. Such a categorical and positively identification of an accused, without any showing of
ill-motive on the motive on the part of the witness testifying on the matter, prevails over the alibi
and denial of the accused which are negative and self-serving evidence undeserving of real
weight in law.
Judgment of CA was affirmed.

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PEOPLE OF THE PHILIPPINES VS.

G.R. NO. 175831

Judgment of CA was affirmed. Penalty of death reduced to reclusion perpetua.

G.R. NO. 158362

Judgment of Ca was affirmed. Penalty of reclusion perpetua was imposed.

G.R. NO. 178406

Judgment of CA was affirmed.

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