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 for failure to prove the physical impossibility of his presence at the crime scene. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, reiterating his alibi and assailing the credibility of the eyewitness.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for Murder based on the positive identification by an eyewitness, despite his defense of alibi.

RULING

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

The Court held that the defense of alibi is inherently weak and cannot prevail over the positive and categorical identification of the accused by a credible eyewitness. 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 location he claimed to be in was merely a few hours away from the crime scene by available transportation.

Furthermore, the Court found no reason to disturb the factual findings of the trial court regarding the eyewitness’s credibility. The witness’s testimony was clear, consistent, and given in a straightforward manner, surviving rigorous cross-examination. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor and manner of testifying. Absent any showing of ill motive or palpable error, the Supreme Court will not substitute its own judgment. Thus, the positive identification, which established the accused-appellant’s guilt beyond reasonable doubt, must prevail over the unsubstantiated alibi.