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SECOND DIVISION

G.R. No. 229380, June 06, 2018


LENIZA REYES Y CAPISTRANO, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

The Court finds the version of the prosecution regarding the seizure of the subject item as
lacking in credence. To recapitulate, the prosecution, through the testimony of PO1
Monteras, claimed that when the police officers asked Reyes if she purchased shabu, she
turned her back and voluntarily showed the plastic sachet containing the same which she
retrieved from her brassiere. According to jurisprudence, the issue of credibility of a
witness's testimony is determined by its conformity with knowledge and consistency with
the common experience of mankind. As the Court observes, it is rather contrary to ordinary
human experience for a person to willfully exhibit incriminating evidence which would
result in his or her conviction for a crime, absent any impelling circumstance which would
prompt him or her to do so.
__________________
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
HERMOGENES DE GUZMAN @ Mong, Accused-Appellant.
Furthermore, the reaction of Flores, in hurriedly going home and leaving Urieta alone to die, was
unnatural and contrary to common human experience. The seemingly apathetic behavior
displayed by Flores in leaving Urieta without even checking his condition to see if he was still
breathing and his failure to report the matter to the police or at least inform the victim's family
about what happened on the same night were highly inconsistent with the natural/common
reaction of one who had just witnessed the stabbing of his childhood friend. The Court cannot
accept a story that defies reason and leaves much to the imagination. The failure of Flores to
lend a touch of realism to his tale leads to the conclusion that he was either withholding an
incriminating information or was not telling the truth.
__________________
G.R. No. 185715 January 19, 2011
PEOPLE OF THE PHILIPPINES, Appellee,
vs.
ERLINDA CAPUNO y TISON, Appellant.
In sustaining the appellant’s conviction, the CA also relied on the evidentiary presumption
that official duties have been regularly performed. This presumption, it must be stressed, is
not conclusive. We are at a loss how PO1 Antonio and PO1 Jiro could have given different
accounts regarding how the confidential asset informed them of the appellant’s illegal
activities when both of them were present at the police station on July 21, 2002. What
baffles us even more is why PO1 Jiro’s gave conflicting statements in his joint affidavit and
in his court testimony. To us, the conflicting statements and declarations of PO1 Antonio and
PO1 Jiro destroyed their credibility; it made their testimonies unreliable. Evidence to be believed
must not only proceed from the mouth of a credible witness but it must be credible in itself, such
as the common experience and observation of mankind can approve as probable under
the circumstances.
__________________
G.R. No. 190178 February 12, 2014

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,


vs.
FELIMON PATENTES y ZAMORA, Accused-Apellant

The time-honored test in determining the value of the testimony of a witness is its compatibility
with human knowledge, observation and common experience of man.18 Thus, whatever is
repugnant to the standards of human knowledge, observation and experience becomes
incredible and must lie outside judicial cognizance.19

As culled from the records, AAA lived with appellant’s family for eight (8) days – in the same
house where appellant’s parents, sister, brother-in-law, nephews and nieces also lived. AAA
even called appellant’s mother, "mama." As argued by the defense, "the members of the
appellant’s family could have noticed that she was being forced and raped by the accused if the
accusations were really true."20 Indeed, it is incompatible with human experience to keep a sex
slave for eight (8) days in a house where the abuser’s entire family, including the abuser’s minor
nephews and nieces live.

When appellant and AAA arrived in the former’s house, they were greeted by appellant’s father.
If AAA’s account were true that appellant dragged her to a room upstairs and then tied her to a
sewing machine, appellant’s father could have noticed and reacted to the obvious violence. To
say the least, he would have talked to the appellant about the deed. Instead, and incredibly,
appellant’s mother went to AAA’s house to propose marriage – contrary to the common
experience.
__________________
November 29, 2017
G.R. No. 203121

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee


vs.
GOLEM SOTA and AMIDAL GADJADLI, Accused-Appellants
(not contrary to common human experience)

Accused-appellants denigrate as contrary to human experience the testimony of Jocelyn that


Eusebio, having been informed of what had happened to their father, did not make any move to
help him.37
Noteworthy, in People v. Banez,38 the Court ruled that it is not at all uncommon or unnatural for
a witness who, as in this case, having seen the killing of a person, did not even move, help, or
run away from the crime scene, but simply chose to stay and continue plowing. It explained its
ruling as follows:
It is settled that there could be no hard and fast gauge for measuring a person's reaction or
behavior when confronted with a startling, not to mention horrifying, occurrence, as in this case.
Witnesses of startling occurrences react differently depending upon their situation and state of
mind, and there is no standard form of human behavioral response when one is confronted with
a strange, startling or frightful experience. The workings of the human mind placed under
emotional stress are unpredictable, and people react differently to shocking stimulus - some
may shout, some may faint, and others may be plunged into insensibility.39
Jocelyn testified that Eusebio did not help Artemio because he was trembling with fear.
Presumably, Eusebio had been informed by Jocelyn that five malefactors came to Artemio's
house that night. Eusebio's immediate reaction was to cower in fear with concern for his self-
preservation rather than coming to the aid of his father.
__________________
January 17, 2018
G.R. No. 225642-43

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee


vs.
JUVY D. AMARELA AND JUNARD G. RACHO, Accused-Appellant

They argued that there were several circumstances casting doubt on AAA' s claim that she was
raped because her testimony does not conform to common knowledge and to ordinary human
experience. [Racho] would have us believe that the charge against him was merely fabricated
because, according to him, being raped by two different assailants, on two different occasions
and only hours apart, is contrary to the normal course of things.

We are not convinced.

The Supreme Court has once said that rape in itself is prompted by the abnormal need of a man
to overpower and control a woman by way of sexual abuse. There is no typical mode, norm, or
circumstance in committing rape or sexual abuse for the evil in man has no conscience. In fact,
in a catena of cases, the Supreme Court had ruled that rape is no respecter of time or place.
Thus, we cannot agree with [Racho]'s argument that just because [AAA] had been raped five
hours earlier, the possibility that she might get raped again is nil.
__________________

Significance of the Case Study Method in the Study of Law.

Student-centered reflection, in which students have the opportunity to discuss their


understanding of the case, allows both students and instructors to connect active learning
experiences back to a larger theoretical context. Case learning is particularly useful for
dramatizing abstract theoretical concepts, making seemingly distant events or issues seem
more “authentic” or “real,” demonstrating the connection between theory and practice,
and building critical-thinking and problem-solving skills (Inoue & Krain, 2014; Krain, 2010;
Kuzma & Haney, 2001; Lamy, 2007; Swimelar, 2013).

[…]
This study suggests that case-based approaches have great utility in the classroom, and they
should be used more often in instances where students’ understanding of conceptual complexity
or knowledge of case details is critical. Moreover, case-based exercises can be derived from a
variety of different types of materials and still have great utility. If deployed selectively in the
context of a more traditional classroom setting as ways to achieve particular educational
objectives, case-based approaches can be useful tools in our pedagogical toolbox.

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