GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz, whom she had known for five years, stab the victim from behind during a barangay fiesta. The defense interposed alibi, claiming Dela Cruz was in a different city at the time. The Regional Trial Court convicted Dela Cruz of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Dela Cruz now appeals, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, assailing the credibility of the lone eyewitness and the weakness of his alibi as a defense.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged insufficiency of evidence proving his guilt beyond reasonable doubt.

RULING

No, the Court of Appeals did not err. The appeal is denied, and the conviction is affirmed.

The Supreme Court held that the factual findings of the trial court, especially on the credibility of witnesses, are entitled to great weight and respect, and are binding on the Court unless certain exceptional circumstances are present, none of which obtain in this case. The positive identification by the eyewitness, Maria Reyes, who had no ill motive to testify falsely and whose testimony remained consistent and candid on cross-examination, prevails over the weak defense of alibi. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. Dela Cruz failed to establish such physical impossibility. Furthermore, the manner of attacka sudden stabbing from behind without warningindubitably qualifies the killing with treachery, which attended the crime with the certainty and severity necessary for a conviction of Murder. Thus, all elements of Murder under Article 248 of the Revised Penal Code, as amended, have been proven beyond reasonable doubt.