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, interposed the defense of 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 and that his alibi should prevail over the eyewitness account.

ISSUE

Whether the conviction of accused-appellant Juan Dela Cruz for the crime of Murder should be upheld, considering the alleged insufficiency of the prosecution’s evidence and the strength of his defense of alibi.

RULING

NO, the appeal is DENIED. The conviction is AFFIRMED.

The Supreme Court held that the prosecution successfully proved the guilt of the accused beyond reasonable doubt. Positive identification, when categorical, consistent, and without ill motive on the part of the eyewitness, prevails over the defense of alibi. Alibi is inherently weak and must be established by clear and convincing evidence showing the physical impossibility of the accused’s presence at the scene of the crime. In this case, the accused failed to demonstrate such impossibility, as the city where he claimed to be was not so far as to preclude his presence at the crime scene. The trial court’s assessment of the eyewitness’s credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor. There being no evidence of any improper motive for the witness to falsely testify, his positive identification stands. All elements of Murder, including the qualifying circumstance of treachery, were sufficiently proven by the prosecution. Hence, the appealed decision is affirmed in toto.