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, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, as the eyewitness testimony was inconsistent and his alibi was corroborated.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for Murder based on the evidence presented.

RULING

No. The Supreme Court denied the appeal and affirmed the conviction. The Court held that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and entitled to great weight. The alleged inconsistencies in the eyewitness testimony pertained to minor details and did not affect the core fact of positive identification. Alibi is inherently a weak defense and cannot prevail over the positive and categorical testimony of a credible witness who identified the accused as the author of the crime. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed 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. Thus, the prosecution successfully proved all the elements of Murder and the qualifying circumstance of treachery beyond reasonable doubt. The decision of the Court of Appeals is affirmed in toto.