Testimony of child-victims.- “Courts expect minor inconsistencies when a child-victim narrates the details of a harrowing experience like rape. Such inconsistencies on minor details are in fact badges of truth, candidness and the fact that the witness is unrehearsed. These discrepancies as to minor details, irrelevant to the elements of the crime, cannot thus, be considered a ground for acquittal.[1]
“A victim of tender age would not have narrated such sordid details had she not experienced them. In a long line of cases, the Court has given full weight and credit to the testimony of child-victims. For it is highly improbable that a girl of tender years would impute to any man a crime so serious as rape if what she claims is not true.”[2] (Citations omitted)
“XX. It has been repeatedly held that when the offended party is of tender age and immature, courts are inclined to give credit to her account of what transpired, considering not only her relative vulnerability but also the shame to which she would be exposed if the matter to which she testified is not true. Youth and immaturity are generally badges of truth and sincerity.[3]
“Courts accord full weight and credit to the testimonies of child victims, for when a woman or a girl-child says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed.”[4] When the offended party is of tender age and immature, courts are inclined to give credit to her account of what transpired, considering not only her relative vulnerability, but also the shame to which she would be exposed if the matter to which she testified is not true.[5]
“This Court has held that crying of the victim during her testimony is evidence of the credibility of the rape charge with the verity born out of human nature and experience.”[6]
[1] People v. Lagbo, 780 Phil. 834 (2016), cited in People v. ZZZ, G.R. no. 232329. April 28, 2021
[2] People v. Dumdum, G.R. No.221436, June 26, 2019
[3] People v. XXX, G.R. No. 230334, August 19, 2019; People v. Eulalio, G.R. No. 214882, October 6, 2019; People v. ABC, G.R. No. 224835, December 11, 2019; BBB v. People, G.R.No. 249307, August 27, 2020; People v. XXX, G.R. No. 239906, August 26, 2020; People v. Barrera, G.R. No. 230549, December 1, 2020; People v. XXX, G.R. No. 238405, December 7, 2020
[4] People v. Alberca, G.R. No. 217459, June 7, 2017, cited in People v. Danao, G.R. No. 233252, August 14, 2019; People v. ABC. G.R. No. 224835, December 11, 2019; People v. Quinto, G.R. No. 246460, June 8, 2020; ABC v. People, G.R. No. 241581, July 8, 2020; People v. Manlolo, G.R. No. 227841, August 19, 2020; People v. Talmesa, G.R. No. 240421, November 16, 2020
[5] People v. XXX, G.R. No. 239906, August 26, 2020
[6] People v. Ortiz, 614 Phil. 625 (2009) cited in People v., Jagdon, Jr., G.R. No.242882, September 9, 2020