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 had known for five years, stab the victim during a street altercation. 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 positive identification by the eyewitness 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, emphasizing the inherent weakness of alibi as a defense and questioning the credibility of the single eyewitness.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for Murder based on the testimony of a single eyewitness, despite the defense of alibi.

RULING

No, the Court of Appeals did not err.

The Supreme Court affirmed the conviction. The Court held that the defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. In this case, the accused-appellant failed to demonstrate such physical impossibility, as the city he claimed to be in was merely a few hours away by vehicle.

Regarding the testimony of a single eyewitness, the Court reiterated the well-established doctrine that the testimony of a single witness, if positive and credible, is sufficient to support a conviction. The credibility of witnesses is best assessed by the trial court, which has the unique opportunity to observe their demeanor, conduct, and attitude on the stand. The trial court found the eyewitness, Maria Reyes, to be straightforward, consistent, and unwavering in her identification of the accused-appellant, whom she knew personally. There was no evidence of any ill motive on her part to falsely testify. Absent any showing that the trial court overlooked material facts or gravely abused its discretion, its findings on credibility are accorded great weight and respect.

Thus, the positive identification by a credible eyewitness, which established the accused-appellant’s presence and participation at the crime scene, prevails over the unsubstantiated defense of alibi. The guilt of Juan Dela Cruz for the crime of Murder was proven beyond reasonable doubt.