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 eyewitness testimony 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 corroborated.

ISSUE

Whether or not the Court of Appeals erred in affirming the conviction of accused-appellant for Murder, despite the alleged inconsistencies in the eyewitness account and the corroborated defense of alibi.

RULING

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

The Court held that the alleged inconsistencies in the eyewitness testimony pertained to minor and trivial details, which did not detract from the witness’s positive identification of the accused. Such minor inconsistencies may even enhance the credibility of the witness, as they negate any suspicion of rehearsed testimony. The eyewitness gave a clear, categorical, and consistent account on the material pointthat he saw accused-appellant deliver the fatal stab wound to the victim.

Furthermore, the defense of alibi must be rejected. 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 failed to establish such physical impossibility. The other city where he claimed to be was merely a few hours away by land travel, making it possible for him to have been at the crime scene. Alibi is inherently weak and cannot prevail over the positive identification by a credible witness. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witnesses’ demeanor. Finding no reversible error in the lower courts’ rulings, the conviction stands.