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 the accused-appellant for Murder based on the eyewitness identification, despite the defense of alibi.

RULING

No. The Court of Appeals did not err. The conviction is affirmed.

The Supreme Court held that the positive identification of the accused by a credible eyewitness who had no ill motive to testify falsely prevails over the defense of alibi and denial. The Court found the testimony of the prosecution witness to be clear, categorical, and consistent on material points, thereby withstanding the test of rigorous cross-examination. The alleged inconsistencies referred to by the defense were minor and did not affect the witness’s core narrative of witnessing the crime.

Furthermore, the defense of alibi is inherently weak and must be supported by clear and convincing evidence. 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. In this case, the accused failed to establish the element of physical impossibility, as the distance between the crime scene and the location of his alleged alibi was not insurmountable within the timeframe of the incident. Corroborating witnesses for the alibi, being friends and relatives of the accused, are considered biased and their testimonies carry less weight.

Thus, the prosecution successfully discharged its burden of proving the guilt of the accused beyond reasonable doubt. The elements of Murder, including the qualifying circumstance of treachery, were sufficiently established by the evidence on record. The decision of the Court of Appeals is hereby AFFIRMED in toto.