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, qualified by treachery, and sentenced him to reclusion perpetua. 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 identification.

ISSUE

Whether the conviction of accused-appellant Juan Dela Cruz for the crime of Murder is supported by proof beyond reasonable doubt.

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 gains strength and becomes credible when the prosecution’s evidence itself is weak and insufficient to prove the accused’s guilt beyond 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 circumstances severely undermine the reliability of his identification. The prosecution failed to present any corroborating evidence, such as physical evidence or motive, to bolster its case. Between the positive but doubtful testimony of the eyewitness and the credible, corroborated, and physically impossible-to-be-present alibi of the accused, the latter must prevail. The constitutional presumption of innocence, coupled with the prosecution’s failure to discharge its burden of proof, mandates an acquittal. Where the evidence does not fulfill the test of moral certainty and leaves room for reasonable doubt, the accused is entitled to an acquittal, as it is better to liberate a guilty man than to unjustly imprison an innocent one.