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 or not the conviction of accused-appellant Juan Dela Cruz for the crime of Murder should be upheld, considering the alleged inconsistencies in the eyewitness identification and the strength of his defense of alibi.

RULING

No. The appeal is granted. The conviction is REVERSED and SET ASIDE. Accused-appellant Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.

The Supreme Court held that for a conviction to stand, the prosecution must prove the guilt of the accused beyond reasonable doubt. In this case, the Court found material inconsistencies in the eyewitness’s testimony regarding material points such as the lighting conditions, the distance from the event, and the specific identifying features of the assailant, which cast serious doubt on its reliability. Positive identification, to be believed, must not only come from a credible witness but must also be unequivocal and free from doubt. Meanwhile, the defense of alibi, while generally weak, gains strength where, as here, it was physically impossible for the accused to have been at the crime scene, and such claim is supported by credible corroborating witnesses whose testimonies remained consistent and unshaken on cross-examination. Where the prosecution’s evidence does not overcome the presumption of innocence, and the evidence for the defense creates reasonable doubt, the scales of justice must tilt in favor of the accused. An acquittal is thus mandated.