GR No. 123456, *People v. Dela Cruz* (2020)

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. The defense interposed alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz of Murder qualified by treachery, finding the eyewitness testimony credible and the alibi weak. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not sufficiently established.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of Murder.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction for Murder.

The Court held that the positive identification of the accused by the eyewitness, who had no ill motive to testify falsely, prevails over the defense of alibi which was not physically impossible. The witness’s clear and categorical testimony, corroborated by physical evidence, established the identity of the perpetrator and his criminal act beyond reasonable doubt.

Furthermore, the Court ruled that treachery (alevosia) was duly proven. The evidence showed that the attack was sudden and unexpected, employing means that deprived the victim of any opportunity to defend himself or retaliate. The victim was stabbed from behind without any provocation, satisfying the elements of treachery which qualifies the killing as Murder under Article 248 of the Revised Penal Code.

The decision of the Court of Appeals is affirmed in toto.