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 street altercation. 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 failure to establish treachery.

ISSUE

1. Whether the testimony of the lone eyewitness, Maria Reyes, is credible and sufficient to sustain a conviction for Murder.
2. Whether the qualifying circumstance of treachery was proven beyond reasonable doubt.

RULING

1. Yes, the testimony of the lone eyewitness is credible and sufficient to sustain the conviction. The Court has consistently held that the testimony of a single witness, if positive and credible, is sufficient to support a conviction. Here, Maria Reyes gave a clear, straightforward, and consistent narration of the incident. She had no ill motive to falsely testify against the accused, and her familiarity with him for five years negates any possibility of mistaken identity. The defense of alibi is inherently weak and cannot prevail over the positive identification by a credible witness. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor.

2. No, the qualifying circumstance of treachery was not proven beyond reasonable doubt. For treachery to qualify the killing to Murder, two conditions must concur: (a) the employment of means of execution that gives the person attacked no opportunity to defend himself or retaliate; and (b) the means of execution were deliberately or consciously adopted. The prosecution evidence merely showed that the victim was stabbed from behind during a sudden altercation. There was no evidence that the accused deliberately employed a specific method to ensure the execution of the crime without risk to himself. The suddenness of the attack, without more, does not automatically constitute treachery. The killing is thus properly classified as Homicide, not Murder.

WHEREFORE, the appeal is PARTIALLY GRANTED. The Decision of the Court of Appeals is MODIFIED. Accused-appellant Juan Dela Cruz is found guilty of HOMICIDE only, and is sentenced to an indeterminate penalty of eight (8) years and one (1) day of *prision mayor* as minimum, to fourteen (14) years, eight (8) months and one (1) day of *reclusion temporal* as maximum. He is ordered to pay the heirs of Pedro Santos civil indemnity, moral damages, and temperate damages, all with legal interest.