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 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 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, highlighting inconsistencies in the eyewitness’s testimony and the weakness of the alibi defense alone not being sufficient for conviction.

ISSUE

Whether or not the court a quo erred in convicting accused-appellant of Murder based on the positive identification by a single eyewitness, despite alleged inconsistencies, and in rejecting the defense of alibi.

RULING

No, the court a quo did not err. The appeal is denied, and the conviction is affirmed.

The Supreme Court held that the positive identification of the accused by a credible eyewitness who had no ill motive to testify falsely prevails over the defense of alibi and denial. The alleged inconsistencies in the testimony of Maria Reyes pertained to minor details and did not affect the core of her testimonythat she saw Dela Cruz stab the victim. Such minor inconsistencies may even enhance credibility, as they indicate spontaneity and lack of rehearsal. The defense of alibi is inherently weak and must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the crime scene. Dela Cruz failed to prove such impossibility, as the city where he claimed to be was not so distant as to preclude his presence at the crime scene. Furthermore, treachery was correctly appreciated, as the attack was sudden and from behind, depriving the victim of any chance to defend himself. Thus, all elements of Murder under Article 248 of the Revised Penal Code were proven beyond reasonable doubt.