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 or not the conviction of accused-appellant Juan Dela Cruz for the crime of Murder should be upheld.

RULING

NO. The conviction is REVERSED and SET ASIDE. Accused-appellant Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.

The Court held that while alibi is inherently a weak defense, it assumes significance and may prevail when the prosecution’s evidence itself is weak and fails to meet the test of moral certainty. In this case, the lone eyewitness’s identification was fraught with serious doubts. The witness admitted during cross-examination that the incident occurred at night in a poorly lit area, and he only had a fleeting glance at the assailant from a considerable distance. These material inconsistencies and the inherent weakness of the identification under the prevailing conditions cast reasonable doubt on the veracity of the testimony. The prosecution therefore failed to discharge its burden of proving the identity of the perpetrator beyond reasonable doubt. Where the prosecution’s evidence does not overcome the presumption of innocence, the defense of alibi, though weak, must be sustained. Accordingly, accused-appellant is entitled to an acquittal.