WITNESSESCredibility of a Mentally Retarded Witness

People of the Philippines v. Ninoy Rosales y EstoG.R. No.197537July 24, 2013

Doctrine:

A deaf-mute may not be able to hear and speak but his/her other senses, such as his/her sense of sight, remain functional and allow him/her to make observations about his/her environment and experiences; Thus, a deaf-mute is competent to be a witness so long as he/she has the faculty to make observations and he/she can make those observations known to others.

RAPE CASESConviction based on Sole Testimony of Victim

People of the Philippines v. Edmundo ViteroG.R. No. 175327April 3, 2013

Doctrine:

In a prosecution for rape, the accused may be convicted solely on the basis of the testimony of the victim that is credible, convincing, and consistent with human nature and the normal course of things, as in this case.

The Supreme Court held that different people react differently to different situations and there is no standard form of human behavioral response when one is confronted with a frightful experience. While the reaction of some women, when faced with the possibility of rape, is to struggle or shout for help, still others become virtually catatonic because of the mental shock they experience. In the instant case, it is not inconceivable or improbable that [private complainant], being of tender age, would be intimidated into silence by the threats and actions of her father.

PHYSICIAN-PATIENT PRIVILEGED COMMUNICATION

Josielene Lara Chan v. Johnny T. Chan G.R. No. 179786July 24, 2013

Doctrine:

Physician-patient privileged communication rule essentially means that a physician who gets information while professionally attending a patient cannot in a civil case be examined without the patient’s consent as to any facts which would blacken the latter’s reputation. The time to object to the admission of evidence would be at the time they are offered. The offer could be made part of the physician’s testimony or as independent evidence that he had made entries in those records that concern the patient’s health

problems. To allow, however, the disclosure during discovery procedure of the hospital records—the results of tests that the physician ordered, the diagnosis of the patient’s illness, and the advice or treatment he gave him—would be to allow access to evidence that is inadmissible without the patient’s consent.

RAPE CASESConviction based on Sole Testimony of Victim

People of the Philippines v. Edmundo ViteroG.R. No. 175327April 3, 2013

Doctrine:

In a prosecution for rape, the accused may be convicted solely on the basis of the testimony of the victim that is credible, convincing, and consistent with human nature and the normal course of things, as in this case.

The Supreme Court held that different people react differently to different situations and there is no standard form of human behavioral response when one is confronted with a frightful experience. While the reaction of some women, when faced with the possibility of rape, is to struggle or shout for help, still others become virtually catatonic because of the mental shock they experience. In the instant case, it is not inconceivable or improbable that [private complainant], being of tender age, would be intimidated into silence by the threats and actions of her father.

SUBSTANTIAL EVIDENCE

Office of the Ombudsman v. Arnel A. BernardoG.R. No. 181598March 6, 2013

Doctrine:

Administrative proceedings are governed by the “substantial evidence rule.” Otherwise stated, a finding of guilt in an administrative case would have to be sustained for as long as it is supported by substantial evidence that the respondent has committed acts stated in the complaint. Substantial evidence is more than a mere scintilla of evidence. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, even if other minds equally reasonable might conceivably opine otherwise.

SUMMARY OF DOCTRINES ON RULES OF EVIDENCE

Submitted by:

Emelita C. Basan

Submitted to:

Judge Francisco V.L. Collado, Jr.