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 knew personally, stab the victim from behind in a dimly lit alley. 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 the circumstantial evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

No. The appeal is denied. The Court of Appeals decision is affirmed.

The Supreme Court held that the prosecution successfully proved all the elements of Murder. The positive and categorical identification by eyewitness Maria Reyes, who had no ill motive to falsely testify, prevails over the weak defense of alibi. The Court found her testimony clear, consistent, and credible, surviving rigorous cross-examination. Her familiarity with the accused bolstered the reliability of her identification. Treachery was correctly appreciated as the attack was sudden and from behind, depriving the victim of any opportunity to defend himself. The defense of alibi, uncorroborated and not physically impossible, must fail. The findings of fact and assessment of witness credibility by the trial court, affirmed by the Court of Appeals, are entitled to great weight and respect, and find no reason to be overturned. Thus, the conviction for Murder is upheld.