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 eyewitness testimony and forensic evidence. The defense interposed alibi and denial, 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 prosecution’s evidence credible and sufficient to establish guilt beyond reasonable doubt. The Court of Appeals affirmed the conviction in toto. Dela Cruz now appeals before the Supreme Court, arguing that the lower courts gravely erred in giving credence to the inconsistent testimonies of the prosecution witnesses and in appreciating the qualifying circumstance of treachery.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of Murder.

RULING

No. The Court of Appeals did not err. The conviction for Murder is affirmed.

The Supreme Court held that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive. The alleged inconsistencies in the testimonies of the prosecution witnesses pertained to minor and trivial details which did not affect the core narrative of the crime and, in fact, enhanced their credibility by negating any suspicion of rehearsed testimony. The essential elements of the crime of Killing (Article 248 of the Revised Penal Code) were proven beyond reasonable doubt: (1) that a person was killed; (2) that the accused killed him; and (3) that the killing was attended by any of the qualifying circumstances, such as treachery.

The Court found that treachery (alevosia) was duly established. The attack was sudden and unexpected, employing means that deprived the victim of any opportunity to defend himself or retaliate. The manner of execution, a swift stab from behind without any provocation or warning, directly and specifically ensured the execution of the crime without risk to the assailant. The defense of alibi and denial must fail in light of the positive identification by credible witnesses. Alibi is inherently weak and cannot prevail over the categorical testimony of an eyewitness. Denial, like alibi, is an intrinsically feeble defense which assumes no weight when placed against affirmative testimony. Thus, the guilt of accused-appellant Juan Dela Cruz for the crime of Murder has been established with moral certainty. The penalty and damages awarded by the lower courts are sustained.