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. 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 now appeals, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, assailing the credibility of the lone eyewitness and insisting on his alibi.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

No, the Court of Appeals did not err. The appeal is denied, and the conviction is affirmed.

The Supreme Court held that the findings of fact of the trial court, especially on the credibility of witnesses, are entitled to great weight and respect, and are binding on the appellate courts, unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case. In this instance, no such oversight exists. The positive identification by the eyewitness, who had no ill motive to testify falsely, prevails over the defense of alibi, which is inherently weak and easily fabricated. Alibi cannot stand against the positive testimony of a credible witness that the accused perpetrated the crime. Moreover, the elements of Murder were sufficiently established: (1) a person was killed; (2) the accused killed him; (3) the killing was attended by treachery; and (4) the killing is not parricide or infanticide. The sudden and unexpected attack on the unarmed victim, depriving him of any chance to defend himself, constituted treachery. The defense failed to show any reversible error in the assailed decisions. Hence, the guilt of accused-appellant was proven beyond reasonable doubt.