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 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, as the eyewitness testimony was inconsistent and his alibi was supported by corroborating witnesses.

ISSUE

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

RULING

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

The Court held that the positive identification of the accused by a credible eyewitness who had no ill motive to testify falsely prevails over the defense of alibi. Alibi is inherently weak and must be established with clear and convincing evidence that it was physically impossible for the accused to have been at the scene of the crime. In this case, the distance between the crime scene and the location where the accused claimed to be was not so great as to preclude his presence at the former. The alleged corroborating witnesses for the alibi were also found to be biased, being relatives of the accused. Conversely, the eyewitness gave a consistent and straightforward account of the incident, and her testimony was corroborated by physical evidence. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe their demeanor. Thus, the prosecution successfully proved all the elements of Murder, including the qualifying circumstance of treachery, beyond reasonable doubt.