Rule on Partial Credibility of a witness

The testimony of a witness may be believed in part and disbelieved in another part, depending on the
probabilities and improbabilities of the case.

If the testimony of the witness on a material issue- it means heart of the issue- is willfully false and
given with an intention to deceive, the court may disregard all the witness’ testimony. Falsus in uno,
falsus in omnibus (False in one thing, false in everything).

On Appeal- The trial court’s findings of fact will not be disturbed on appeal, unless there is a clear
showing that it plainly overlooked matters of substance which, if considered, might affect the results of
the review. The credibility of witnesses is best determined by the trial judge, who has the direct
opportunity to observe and evaluate their demeanor on the witness stand.

May the uncorroborated testimony of an accused who turned into a State witness suffice to convict his
co-accused?

Yes. It may suffice to convict his co-accused if it is given unhesitatingly and in a straightforward
manner and is full of details which by their nature could not have been the result of deliberate
afterthought, otherwise, it needs corroboration, the presence or lack of which may ultimately
decide the case of the prosecution and the fate of the accused.

May the testimony alone of the complaining party in a rape case sufficient to convict the accused?

Yes. In rape cases, the lone testimony of the offended party, if free from serious and material
contradictions, is sufficient to sustain a verdict of conviction. No woman would openly admit that she
was raped and consequently subject herself to an examination of her private parts, undergo the trauma
and humiliation of a public trial, and embarrass herself with the need to narrate in detail how she was
raped, if she was not raped at all. This ruling especially holds true where the complainant is a minor,
whose testimony deserves full credence.

What is the Sweetheart Theory?

It is an admission by the accused of sexual intercourse with the victim but argues that they were
lovers and the act is consensual and consequently places on the accused the burden of proving
the supposed relationship by substantial evidence. To be worthy of judicial acceptance, such
defense should be supported by documentary, testimonial, or other evidence. Corroborative
proof like notes, pictures or tokens that such a relationship had really existed must be presented
(People v. Hapin, G.R. No.175782, Aug. 24, 2007).

Is extrajudicial confession a sufficient ground for conviction?

 It is not sufficient ground for conviction unless corroborated by evidence of corpus delicti.
Corpus delicti refers to the body of the crime take note of this. It is the actual commission by someone
of the particular crime charged. It refers to the fact of the commission of the crime, not to the physical
body of the deceased or to the ashes of a burned building. The corpus delicti may be proven by the
credible testimony of a sole witness, not necessarily by physical evidence.

What are the elements of illegal possession of firearm which constitute the corpus delicti?

1. The existence of the firearm; and

2. That it has been actually held with animus possidendi by the accused without the
corresponding license therefor.