Jurisprudence on Credibility of Witness

I.
Macayan vs. People of the Philippines G.R. No. 175842 March 18, 2015
“For evidence to be believed, however, it must not only proceed from the
mouth of a credible witness but must be credible in itself such as the common
experience and observation of mankind can approve under the circumstances.
The test to determine the value of the testimony of a witness is whether such is
in conformity with knowledge and consistent with the experience of mankind.
Whatever is repugnant to these standards becomes incredible and lies outside
of judicial cognizance. Jao’s inconsistent conduct, coupled with flimsy
justifications for acting as she did, betrays the absurdity and unreliability of
her claims and ultimately, of her as a witness.
xxxxx
In criminal cases, the prosecution has the onus probandi of establishing the
guilt of the accused. Ei incumbit probatio non qui negat. He who asserts - not he who
denies - must prove. The burden must be discharged by the prosecution on the
strength of its own evidence, not on the weakness of that for the defense. Hence,
circumstantial evidence that has not been adequately established, much less
corroborated, cannot be the basis of conviction. Suspicion alone is insufficient, the
required quantum of evidence being proof beyond reasonable doubt. Indeed, "the
sea of suspicion has no shore, and the court that embarks upon it is without rudder
or compass."
It must be stressed that in our criminal justice system, the overriding
consideration is not whether the court doubts the innocence of the accused, but
whether it entertains a reasonable doubt as to their guilt. Where there is no moral
certainty as to their guilt, they must be acquitted even though their innocence may
be questionable. The constitutional right to be presumed innocent until proven guilty
can be overthrown only by proof beyond reasonable doubt.” (quoting People of the
Philippines v. Asis, 439 Phil. 707. 7'27-728 (2002)) (emphasis supplied)

II.
 People of the Philippines vs. Capuno G.R. No. 185715 January 19, 2011
“We are at a loss how PO1 Antonio and PO1 Jiro could have given different
accounts regarding how the confidential asset informed them of the appellant’s
illegal activities when both of them were present at the police station on July 21,
2002. What baffles us even more is why PO1 Jiro’s gave conflicting statements
in his joint affidavit and in his court testimony. To us, the conflicting statements
and declarations of PO1 Antonio and PO1 Jiro destroyed their credibility; it
made their testimonies unreliable. Evidence to be believed must not only
proceed from the mouth of a credible witness but it must be credible in itself,
such as the common experience and observation of mankind can approve as
probable under the circumstances.” (emphasis supplied)

III.
People vs. De Guzman G.R. No. 192250 July 11, 2012
“The time-honored test in determining the value of the testimony of a
witness is its compatibility with human knowledge, observation and common
experience of man. Thus, whatever is repugnant to the standards of human
knowledge, observation and experience becomes incredible and must lie outside
judicial cognizance. Consistently, the Court has ruled that evidence to be
believed must proceed not only from the mouth of a credible witness but must
be credible in itself as to hurdle the test of conformity with the knowledge and
common experience of mankind. In the case at bench, the testimony of Flores, the
lone eyewitness of the prosecution does not bear the earmarks of truth and, hence,
not credible.
xxxx
In light of the weakness in the prosecution's case, the alibi of De Guzman
assumes credence and importance. While alibi is a weak defense and the rule is that
it must be proved to the satisfaction of the court, the said rule has never been intended
to change the burden of proof in criminal cases. Otherwise, an absurd situation will
arise wherein the accused is put in a more difficult position where the prosecution
evidence is vague and weak as in the present case. The burden of proof still lies in
the prosecution to establish that De Guzman was responsible for the killing.
 It is oft-repeated that a finding of guilt must rest on the evidence of the
prosecution not on the weakness or even absence of evidence for the defense. Thus,
it is required that every circumstance favoring the innocence of the accused must be
duly taken into account. The proof against him must survive the test of reason and
the strongest suspicion must not be permitted to sway judgment.” (emphasis
supplied)

IV

People vs Laurente G.R. No. L-129594 March 7, 2001

“For evidence to be believed, it must not only proceed from the mouth of a
credible witness but must be credible in itself such as the common experience and
observation of mankind can approve as probable under the circumstances. The test
to determine the value of the testimony of a witness is whether such is in conformity
with knowledge and consistent with the experience of mankind. Whatever is
repugnant to these standards becomes incredible and lies outside of judicial
cognizance. (quoting People v. San Juan, G.R. No. 130969, February 29, 2000)
Complainant's credibility is further eroded by inconsistencies between
her sworn statement, on the one hand, and her court testimony, on the other
hand. In her sworn statement, she stated: "That Junnifer, once inside, reclosed and
locked the door and windows and suddenly grabbed me by the arm, covered my
mouth with a piece of cloth and without a word begun touching my private parts ---
from my breast down to my sexual organ." In her testimony during cross-
examination, however, complainant insisted that accused-appellant only locked the
door but not the window. She admitted that her affidavit does not state that particular
event correctly. She further admitted that accused-appellant did not touch her private
parts but instead immediately proceeded to remove her shorts and panty. Also, she
alleged in her sworn statement that it took hours before she regained consciousness,
after which she immediately went home to San Nicolas and confided the incident to
her my mother who, in turn, brought her to the police precinct. However, she refuted
herself in open court when she declared that her statement in her affidavit that she
lost consciousness was not true.
While the above inconsistencies do not directly touch on the whys and
wherefores of the alleged crime, it is difficult to nonchalantly dismiss them
outright taking into consideration her assertion in her oral testimony that what
she stated to in her affidavit were actually not true. Her declarations, taken
together with her other inconsistent statements on direct and cross-
examination, as well as her actuations after the supposed rape, all betray her
lack of trustworthiness and credibility. Significantly, the prosecution did not
attempt to offer any plausible explanation to these conflicting statements made
by complainant herself.” (emphasis supplied)