“Second, the appellant asserts that the trial judge erred by failing to address concerns about the respondents’ reliability, focusing only on their credibility.
I do not accept this submission. A trial judge’s determination to accept a witness’s evidence includes an implicit assessment of its accuracy or reliability. The trial judge is presumed to have correctly applied the law in accepting a witness’s evidence, including the relationship between credibility and reliability: G.F., at para. 82. Assessing reliability is “within the province of the trial judge” who has “the opportunity to hear and observe all of the witnesses”: R. v. Slatter, 2019 ONCA 807, 148 O.R. (3d) 81, at para. 118, per Pepall J.A. (dissenting), aff’d 2020 SCC 36. If the trial judge was alive to reliability concerns, considered those concerns, and assessed the witness’s reliability and credibility, the trial judge’s assessment attracts deference: R. v. Sanichar, 2012 ONCA 117, 280 C.C.C. (3d) 500, at para. 82, per Laskin J.A. (dissenting), aff’d, 2013 SCC 4, [2013] 1 S.C.R. 54.”