July 2012 Philippine Supreme Court Decisions on Criminal Law and Procedure

Here are select July 2012 rulings of the Supreme Court of the Philippines on criminal law and procedure:


Rape; principles in deciding rape cases. Antonio Baraoil was found guilty by the lower courts for two crimes of rape defined and penalized under RA 8353 and the Revised Penal Code. Courts use the following principles in deciding rape cases: (1) an accusation of rape can be made with facility; it is difficult to prove but more difficult for the person accused, though innocent, to disprove; (2) due to the nature of the crime of rape in which only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits and cannot be allowed to draw strength from the weakness of the evidence for the defense. Due to the nature of this crime, conviction for rape may be solely based on the complainant’s testimony provided it is credible, natural, convincing, and consistent with human nature and the normal course of things. The Supreme Court (“SC”) held in the instant case that the totality of the evidence adduced by the prosecution proved the guilt of the accused-appellant beyond reasonable doubt. The SC finds no cogent reason to disturb the trial court’s appreciation of the credibility of the prosecution witnesses’ testimony. People of the Philippines v. Antonio Baraoil, G.R. No. 194608, July 9, 2012.

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