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 weakness of his alibi as evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder based on the positive identification by a credible eyewitness, despite the defense of alibi.

RULING

No, the Court of Appeals did not err. The appeal is denied, and the conviction is affirmed.

Positive identification, when categorical and consistent and without any ill motive on the part of the eyewitness, prevails over alibi and denial. In this case, the eyewitness, Maria Reyes, gave a clear, straightforward, and unwavering account of the incident. She had no motive to falsely testify against the accused-appellant. Her familiarity with Dela Cruz for a significant period negates any possibility of mistaken identity. Alibi is inherently a weak defense and cannot stand where the accused has been positively identified. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the scene of the crime. Dela Cruz failed to establish such physical impossibility. The elements of Murder, with treachery as a qualifying circumstance, were sufficiently proven by the prosecution. The trial court’s assessment of witness credibility, affirmed by the appellate court, is entitled to great weight and respect. Thus, the guilt of accused-appellant Juan Dela Cruz was proven beyond reasonable doubt.