GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Robbery with Homicide. The prosecution presented evidence that Dela Cruz entered the victim’s home, took a wallet, and, upon being discovered by the homeowner, stabbed the latter, causing his death. The defense claimed that Dela Cruz was merely present at the scene but did not commit the robbery or the killing. The Regional Trial Court convicted Dela Cruz, finding the testimony of a lone eyewitness credible and sufficient to establish guilt beyond reasonable doubt. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that the testimony of a single witness is insufficient for a conviction of a capital offense.

ISSUE

Whether the testimony of a single eyewitness is sufficient to sustain a conviction for the crime of Robbery with Homicide.

RULING

YES, provided the testimony meets the tests of credibility.
The Supreme Court affirmed the conviction. The Court held that the number of witnesses required is not a matter of quantity but of quality. There is no rule of law which states that the testimony of a single witness cannot be believed or that a conviction based on such testimony is invalid. The well-established rule is that the testimony of a single witness, if positive and credible, is sufficient to support a conviction even for a grave offense, as long as it satisfies the court beyond reasonable doubt as to the guilt of the accused. The Court reiterated the criteria for evaluating witness credibility: the witness must be shown to have been present at the scene of the crime and to have actually witnessed the criminal act, and his or her testimony must be clear, straightforward, convincing, and consistent with human nature and the normal course of things. In this case, the Supreme Court found that the lone eyewitness testified in a categorical, spontaneous, frank, and consistent manner, and her testimony withstood rigorous cross-examination. Her positive identification of Dela Cruz as the perpetrator, corroborated by the physical evidence and the chain of events, was deemed more than sufficient to establish moral certainty and to overcome the constitutional presumption of innocence. The appeal was denied, and the decision of the lower courts was affirmed.