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, presented an 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. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, as the eyewitness testimony was inconsistent and his alibi was supported by corroborating witnesses.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged inconsistencies in the eyewitness account and the corroborated defense of alibi.

RULING

No. The Supreme Court denied the appeal and affirmed the conviction.

The Court held that the alleged inconsistencies in the eyewitness testimony pertained to minor details and did not affect the core fact of his positive identification of the accused-appellant as the assailant. Jurisprudence consistently rules that minor inconsistencies may even enhance the credibility of a witness, as they indicate that the testimony was not rehearsed. The categorical, straightforward, and positive identification by the eyewitness, who had no ill motive to testify falsely, prevails over the defense of alibi. Alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to have been at the scene of the crime. In this case, the distance between the crime scene and the location claimed by the alibi was not insurmountable, making physical impossibility non-existent. The corroboration by defense witnesses, being friends and relatives, lacked impartiality. Thus, the prosecution successfully proved all the elements of Murder, including the qualifying circumstance of treachery, beyond reasonable doubt. The decision of the Court of Appeals is affirmed in toto.