Reviewing court bound by trial court's findings

The Supreme Court has always reiterated that the credibility of witnesses is a question best addressed by the trial court because of its opportunity to observe their demeanor while testifying on the stand: an opportunity denied to the appellate courts.[1] Absent any substantial reason to justify the reversal of the trial court's assessment and conclusion, the reviewing court is generally bound by the former's findings, especially when no significant fact nor circumstance is shown to have been overlooked or disregarded which when considered could affect the outcome of the case.[2] The rule is strictly applied when the appellate court affirms the finding of the lower court.

The High Court has also acknowledged that it is difficult to have corroborating testimonies in rape cases since in majority of the cases only the offended party's testimony is available; and has affirmed a conviction of rape as long as it is supported by a conclusive, logical and probable testimony by the offended party.[3]

[1] See People v. Quintos, G.R. No. 199402, November 12, 2014, p. 7.

[2] People v. Laog, G.R. No. 178321, October 5, 2011, 658 SCRA 654, 665-666.

[3] See Peoplev. Pareja, G.R. No. 202122, January 15, 2014, 714 SCRA 131, 151.

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