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 the victim. During trial, the prosecution presented an eyewitness who positively identified Dela Cruz as the perpetrator. The defense, however, interposed the defense of alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz of Murder, finding the positive identification credible and the alibi weak for failure to prove the physical impossibility of being at the crime scene. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the lower courts erred in giving credence to the lone eyewitness account and in not appreciating his defense of alibi.

ISSUE

Whether or not the conviction of accused-appellant Juan Dela Cruz for the crime of Murder is supported by proof beyond reasonable doubt.

RULING

No. The appeal is granted. The Court acquits accused-appellant Juan Dela Cruz on the ground of reasonable doubt.

Positive identification, when categorical, consistent, and without ill motive, prevails over alibi and denial. However, for a conviction to stand, the prosecution must prove the guilt of the accused beyond reasonable doubt. In this case, a review of the records reveals critical lapses in the prosecution’s evidence. The eyewitness testimony, while positive, was fraught with inconsistencies on material points such as the lighting conditions, the relative positions of the accused and the victim, and the sequence of events. These inconsistencies cast serious doubt on the witness’s ability to accurately perceive and recall the identity of the assailant. Furthermore, the prosecution failed to present any corroborative evidence, whether physical or testimonial, to support the lone eyewitness account. The defense of alibi, while generally weak, gains strength where, as here, the prosecution’s evidence is not strong enough to establish moral certainty of the accused’s guilt. Where the evidence for the prosecution is insufficient to surmount the constitutional presumption of innocence, the Court has no alternative but to acquit. The Court reiterates that it is better to acquit a guilty man than to convict an innocent one. Accordingly, accused-appellant Juan Dela Cruz is ACQUITTED and ordered immediately RELEASED from detention, unless he is being held for another lawful cause.