LEGAL PRINCIPLE: CRIMINAL LAW — Armed Robbery — Evaluation of Evidence — Trial Court’s Primary Duty
PRINCIPLE STATEMENT
When a trial court has performed its primary duty of evaluating evidence and made findings that the evidence justifies, an appellate court is not entitled to make contrary findings, especially on credibility.
RATIO DECIDENDI (SOURCE)
Per Uwaifo, JSC, in Isibor v. State (2002) NLC-2462001(SC) at p. 6; Paras B–C.
"When a trial court has performed its primary duty of assessing and evaluating the evidence before it and has made findings of fact which the evidence justifies, an appeal court is not entitled to make contrary findings, particularly when such findings depend largely on the credibility accorded to the witnesses by the trial court. It is normally within the province of the trial court, which has the advantage of hearing and watching witnesses testify, to assess their credibility."
EXPLANATION / SCOPE
The trial court has the primary duty to evaluate evidence and assess witness credibility. The appellate court defers to these findings. The appellate court cannot substitute its own views, especially on credibility. The trial court’s advantage in seeing and hearing witnesses is irreplaceable. The principle applies to both criminal and civil cases. Interference is justified only if the trial court’s findings are perverse or unsupported. The appellant must show manifest error. The rule promotes finality and respects the trial court’s role. The appellate court focuses on errors of law. The trial court’s findings are entitled to deference.