GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Homicide. The prosecution’s case rested primarily on the testimony of a single eyewitness who claimed to have seen the accused stab the victim. The defense presented alibi, claiming the accused was in a different city at the time of the incident. The Regional Trial Court convicted the accused, giving full credence to the eyewitness account. On appeal, the accused argued that his guilt was not proven beyond reasonable doubt, contending that the lone eyewitness testimony was unreliable and inconsistent with physical evidence.

ISSUE

Whether the conviction of the accused based solely on the testimony of a lone eyewitness, whose credibility is seriously challenged, satisfies the requirement of proof beyond reasonable doubt.

RULING

NO. The Court reversed the conviction and acquitted the accused. While a positive identification by a single eyewitness can be sufficient for conviction, such testimony must be credible, trustworthy, and consistent with human experience and the evidence on record. In this case, the eyewitness testimony was fraught with material inconsistencies regarding material details such as distance, lighting, and the sequence of events, which were not adequately explained. These inconsistencies cast serious doubt on the witness’s ability to accurately perceive and recall the incident. Furthermore, the testimony was not corroborated by any other evidence. The constitutional presumption of innocence, coupled with the prosecution’s failure to overcome the burden of proving guilt beyond reasonable doubt, mandates an acquittal. The defense of alibi, while inherently weak, gains strength where, as here, the prosecution’s evidence is itself weak and insufficient. Where the evidence for the prosecution is insufficient to sustain a verdict of guilt, the accused is entitled to an acquittal, regardless of the weakness of the defense evidence.