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 village fiesta. The defense interposed alibi, claiming Dela Cruz was in a different city at the time. The Regional Trial Court convicted Dela Cruz, finding the positive identification by the eyewitness credible and sufficient to overcome the defense of alibi. The Court of Appeals affirmed the conviction. Dela Cruz now appeals, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in the eyewitness’s testimony and the weakness of the alibi defense.

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 and alleged inconsistencies.

RULING

No. The Supreme Court DENIED the appeal and AFFIRMED the conviction.

The Court held that the positive identification of the accused by a credible eyewitness who had no motive to falsely testify prevails over the defense of alibi and denial. The alleged inconsistencies in the witness’s testimony pertained to minor details and did not affect her clear and categorical narration of the central fact of seeing the accused commit the crime. The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was at another place for the entire period of the crime’s commission and that it was physically impossible for him to be at the scene. The accused-appellant failed to establish such physical impossibility. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor. Consequently, all elements of Murder, including treachery (alevosia), were proven beyond reasonable doubt. The appealed decision is affirmed in toto.