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4. People v.

Cepeda By: BMUT


G.R. No. 124832. February 1, 2000 Topic: Admissions of a Party
Ponente: J. Ynares-Santiago
DOCTRINE

Doctrinal guidelines in scrutinizing the credibility of witnesses: first, the appellate tribunal will not disturb the findings of the
lower court unless there is a showing that it had overlooked, misunderstood, or misapplied some fact or circumstance of weight and
substance that would have affected the result of the case; second, the findings of the trial court pertaining to the credibility of
witnesses are entitled to great respect and even finality since it had the opportunity to examine their demeanor as they testified on
the witness stand; and third, a witness who testified in a categorical, straightforward, spontaneous and frank manner and
remained consistent on cross-examination is a credible witness.
.
Facts
 Information for Rape was filed by Conchita Mahomoc at PNP Station of Magallanes.
 2 April 1994: Dante Cepeda (accused) went to the house of Conchita Mahomoc (complainant) and asked her to go to
his house to massage his wife who was having a “stomach ache”. Conchita asked her neighbor Regina Carba to
accompany her. When Conchita and Regina arrived, Dante insisted that Regina had to leave because his wife was a
Muslim and did not want many people inside the house. Regina left.
 Dante led Conchita to the bedroom and saw a figure covered by a blanket whom she presumed to be Dante’s wife.
Immediately, he threatened her with a knife and ordered her to remove her panty and lie on the bed. *Sexual congress
happens*. After he was through, she ran towards the kitchen with Cepeda chasing her. Thus, the complaint.
 Dante alleged that he and Conchita were lovers. He stated that he came to know her as he passes by her house in going to
his place of work; that they already had previous sexual intercourses. He insists that they were carrying an adulterous
love affair.
 Trial Court: rendered judgment against Dante

Issue/s
Whether Dante’s theory should be upheld. – NO.
Ruling
The record shows that other than his self-serving assertions, there is no evidence to support the claim that Dante and Conchita
were in love. It must be noted that Dante and Conchita are both married and are living together with their respective spouses. In
this case, other than Dante;s self-serving testimony, no other evidence like love letters, mementos or pictures were presented to
prove his alleged amorous relationship with Conchita.

Evidence to be believed must not only come from a credible source but must also be credible in itself such as one that the common
experience and observation of mankind can approve as probable under the circumstances. The Court has taken judicial cognizance
of the fact that in rural areas in this country, women by custom and tradition act with circumspection and prudence, and that great
caution is observed so that their reputation remains untainted.

In addition, the mere assertion of a ‘love relationship’ would not necessarily rule out the use of force to consummate the crime. A
sweetheart cannot be forced to have sex against her will. Definitely, a man cannot demand sexual gratification from a fiancee,
worse, employ violence upon her on the pretext of love. Love is not a license for lust.

Importantly, in a prosecution for rape, the evaluation of the evidence presented during trial ultimately revolves around the
credibility of the complaining witness. When a woman says she has been raped, she says in effect all that is necessary to show
that she has been raped and her testimony alone is sufficient if it satisfies the exacting standard of credibility needed to
convict the accused.

In scrutinizing the credibility of witnesses, case law has established the following doctrinal guidelines: first, the appellate tribunal
will not disturb the findings of the lower court unless there is a showing that it had overlooked, misunderstood, or misapplied some
fact or circumstance of weight and substance that would have affected the result of the case; second, the findings of the trial court
pertaining to the credibility of witnesses are entitled to great respect and even finality since it had the opportunity to examine their
demeanor as they testified on the witness stand; and third, a witness who testified in a categorical, straightforward, spontaneous
and frank manner and remained consistent on cross-examination is a credible witness.

Applying these guidelines, the Court found no reason to disturb the following findings and conclusions of the trial court.

WHEREFORE, xxx the decision of the trial court in Criminal Case No. 6246 finding accused Dante Cepeda y Sapotalo guilty
beyond reasonable doubt of the crime of rape is hereby AFFIRMED in all other respects.

Notes

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