GR No. 123456, *People v. Dela Cruz* (2020)

FACTS: Juan Dela Cruz was charged with the crime of robbery. During the trial, the prosecution presented a single eyewitness who identified Dela Cruz as the perpetrator. The defense presented an alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz, giving full credence to the eyewitness testimony and rejecting the alibi. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that his guilt was not proven beyond reasonable doubt, as the conviction rested solely on the uncorroborated testimony of one eyewitness, which was contradicted by his alibi.

ISSUE

Whether the conviction of the accused based solely on the positive identification by a single eyewitness, against whom an alibi was interposed, satisfies the requirement of proof beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Juan Dela Cruz. The Court held that while the testimony of a single eyewitness can be sufficient for a conviction if credible and positive, such testimony must withstand the test of reason and be consistent with human experience. In this case, the prosecution failed to prove the guilt of the accused beyond reasonable doubt. The alibi presented by the defense was supported by credible evidence placing him in a location far from the crime scene, making it physically impossible for him to have committed the robbery. The Court emphasized that when an alibi is corroborated and the prosecution’s evidence is weak, the constitutional presumption of innocence must prevail. The burden of proof lies with the prosecution, and it did not discharge this burden by merely relying on the lone eyewitness account without any corroborative evidence.