In this regard, we defer to the trial court’s assessment of the credibility of AAA’s
testimony, most especially, when it is affirmed by the Court of Appeals. In People v.
Amistoso,15 we reiterated the rationale of this principle in this wise:
Time and again, we have held that when it comes to the issue of credibility of the victim
or the prosecution witnesses, the findings of the trial courts carry great weight and
respect and, generally, the appellate courts will not overturn the said findings unless
the trial court overlooked, misunderstood or misapplied some facts or circumstances of
weight and substance which will alter the assailed decision or affect the result of the
case. This is so because trial courts are in the best position to ascertain and measure
the sincerity and spontaneity of witnesses through their actual observation of the
witnesses’ manner of testifying, their demeanor and behavior in court. Trial judges
enjoy the advantage of observing the witness’ deportment and manner of testifying,
her “furtive glance, blush of conscious shame, hesitation, flippant or sneering tone,
calmness, sigh, or the scant or full realization of an oath” – all of which are useful aids
for an accurate determination of a witness’ honesty and sincerity. Trial judges,
therefore, can better determine if such witnesses are telling the truth, being in the ideal
position to weigh conflicting testimonies. Again, unless certain facts of substance and
value were overlooked which, if considered, might affect the result of the case, its
assessment must be respected, for it had the opportunity to observe the conduct and
demeanor of the witnesses while testifying and detect if they were lying. The rule finds
an even more stringent application where the said findings are sustained by the Court
of Appeals.
chanRoblesvirtual Lawli bra ry
Anent the inconsistent statements made by AAA in her testimony which were pointed
out by appellant, we agree with the assessment made by the Court of Appeals that
these are but minor discrepancies that do little to affect the central issue of rape which
is involved in this case. Instead of diminishing AAA’s credibility, such variance on minor
details has the net effect of bolstering the truthfulness of AAA’s accusations. We have
constantly declared that a few discrepancies and inconsistencies in the testimonies of
witnesses referring to minor details and not in actuality touching upon the central fact
of the crime do not impair the credibility of the witnesses because they discount the
possibility of their being rehearsed testimony.16
Notable is the fact that no ill motive on the part of AAA to falsely accuse appellant was
ever brought up by the defense during trial. This only serves to further strengthen
AAA’s case since we have consistently held that a rape victim’s testimony as to who
abused her is credible where she has absolutely no motive to incriminate and testify
against the accused.17 It is also equally important to highlight AAA’s young age when
she decided to accuse her kin of rape and go through the ordeal of trial. In fact, when
she painfully recounted her tribulation in court, she was just at the tender age of
sixteen (16) years old.18 Jurisprudence instructs us that no young woman, especially of
tender age, would concoct a story of defloration, allow an examination of her private
parts, and thereafter pervert herself by being subjected to public trial, if she was not
motivated solely by the desire to obtain justice for the wrong committed against her.19
In a bid to exculpate himself, appellant argues that he could not have possibly been
guilty of rape because the time period between the rape incidents and the birth of the
alleged fruit of his crime is more than the normal period of pregnancy. He also points
out that defense witness Jackie Gucela’s admission that he was AAA’s lover and the
father of her child should suffice to negate any notion that he raped AAA twice. Lastly,