Credibility of rape victim as found by trial courts binding upon the SC

The Supreme Court now rules on the prosecutions sufficiency of evidence. To sustain a conviction for rape, there must be proof of the penetration of the female organ. In this case, the conviction of accused-appellant was anchored mainly on the testimony of the minor victim, AAA. Accused-appellant, however, questions AAA's credibility, alleging that there was significant discrepancy between her Sinumpaang Salaysay, where she said that she was harassed; and her testimony in court, where she said that she was raped.
The Supreme Court affirms the credibility of AAA. It is a settled doctrine that the trial court's finding of credibility is conclusive on the appellate court, unless it is shown that certain facts of substance and value have been plainly overlooked, misunderstood, or misapplied. In this case, accused-appellant has not shown that the RTC and CA findings should be reversed. As correctly observed by the CA, the inaccuracy in AAA's Sinumpaang Salaysay may be attributed to the inadequacy of the investigators language, and not on her alleged lack of honesty. Moreover, AAA's testimony in court clearly proved that accused-appellant had sexually abused her. It must be stressed that affidavits taken ex parte are inferior to testimony given in court, the affidavits being invariably incomplete and oftentimes inaccurate due to partial suggestions or want of specific inquiries. (G.R. No. 174058; December 27, 2007)

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