Wednesday, March 24, 2021

Inconsistencies and discrepancies as to minor matters irrelevant to the elements of the crime cannot be considered grounds for acquittal.

PEOPLE OF THE PHILIPPINES, appellee, vs. ARTEMIO INVENCION Y SORIANO, appellant. G.R. No. 131636, March 5, 2003. 

https://lawphil.net/judjuris/juri2003/mar2003/gr_131636_2003.html.


“We find as inconsequential the alleged variance or difference in the time that the rape was committed, i.e., during the night as testified to by Elven, or between 6:00 and 7:00 a.m. per the testimony of Eddie. The exact time or date of the commission of rape is not an element of the crime. What is decisive in a rape charge is that the commission of the rape by the accused has been sufficiently proved. Inconsistencies and discrepancies as to minor matters irrelevant to the elements of the crime cannot be considered grounds for acquittal. (People v. Matugas, G.R. Nos. 139698-726, 20 February 2002. See also People v. Alba, 305 SCRA 811 [1999]; People v. Montejo, 355 SCRA 210, 226 [2001]) In this case, we believe that the crime of rape was, indeed, committed as testified to by Elven and Eddie.

The alleged inconsistencies in the testimonies of both Elven and Gloria do not impair the credibility of these witnesses. We agree with the trial court that they are minor inconsistencies, which do not affect the credibility of the witnesses. We have held in a number of cases that inconsistencies in the testimonies of witnesses that refer to minor and insignificant details do not destroy the witnesses’ credibility. (People v. Palomar, 278 SCRA 114, 147 [1997]) On the contrary, they may even be considered badges of veracity or manifestations of truthfulness on the material points in the testimonies. What is important is that the testimonies agree on essential facts and substantially corroborate a consistent and coherent whole. (People v. Gaspar, 318 SCRA 649, 671 [1999])”