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 crime. 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, as the eyewitness testimony was inconsistent and his alibi was corroborated.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged inconsistencies in the eyewitness account and the corroborated defense of alibi.

RULING

No. The Supreme Court denied the appeal and affirmed the conviction.

The Court held that the alleged inconsistencies in the eyewitness testimony pertained to minor details and did not affect the witness’s positive and categorical identification of the accused as the assailant. Jurisprudence consistently rules that minor inconsistencies may even enhance a witness’s credibility, as they indicate that the testimony was not rehearsed. The core testimony of the witnessseeing the accused stab the victimremained clear, consistent, and unwavering.

Furthermore, the defense of alibi must be rejected. For alibi to prevail, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the crime scene. In this case, the accused failed to establish such physical impossibility. The location where he claimed to be was not so distant as to preclude his presence at the locus criminis. Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness.

Thus, the prosecution successfully proved all the elements of Murder, including the qualifying circumstance of treachery, beyond reasonable doubt. The decisions of the lower courts are affirmed.