What is the proper test for sufficiency of evidence in a sexual assault case?

California, United States of America


The following excerpt is from People v. Mateen, E069166 (Cal. App. 2019):

In evaluating a sufficiency of evidence, the proper test is "whether, on the entire record, a rational trier of fact could find the defendant guilty beyond a reasonable doubt. [Citations.] On appeal, we must view the evidence in the light most favorable to the People and must presume in support of the judgment the existence of every fact the trier could reasonably deduce from the evidence." (People v. Jones (1990) 51 Cal.3d 294, 314.) "Although we must ensure the evidence is reasonable, credible, and of solid value, nonetheless it is the exclusive province of the trial judge or jury to determine the credibility of a witness and the truth or falsity of the facts on which that determination depends. [Citation.] Thus, if the verdict is supported by substantial evidence, we must accord due deference to the trier of fact and not substitute our evaluation of a witness's credibility for that of the fact finder. [Citation.]" (Ibid.)

However, "'"an appellate court will not uphold a judgment or verdict based upon evidence inherently improbable."'" (People v. Barnes (1986) 42 Cal.3d 284, 306.) To warrant the rejection of testimony given by a witness at trial who has been believed by the trier of fact, there must exist either a physical impossibility that they are true, or their falsity must be apparent without resorting to inferences or deductions. Conflicts and even testimony which is subject to justifiable suspicion will not justify the reversal of a judgment because a trial judge or jury determines the credibility of a witness and the truth or falsity of the facts. (Ibid.)

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