GR No. 123456, *People v. Dela Cruz* (2020)

FACTS: Juan Dela Cruz was charged with the crime of robbery. During the trial, the prosecution presented a single eyewitness who identified Dela Cruz as the perpetrator. The defense presented an alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz, giving full credence to the eyewitness testimony and rejecting the alibi. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that his guilt was not proven beyond reasonable doubt, as the conviction rested solely on the testimony of one eyewitness, which was contradicted by his alibi.

ISSUE

Whether the conviction of the accused based solely on the positive identification by a single eyewitness, against which an alibi is interposed, satisfies the requirement of proof beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Juan Dela Cruz. The Court held that while the testimony of a single eyewitness can be sufficient for a conviction if it meets the tests of credibility, the evidence in this case failed to establish guilt beyond reasonable doubt. The prosecution’s case relied entirely on one eyewitness whose identification was not unequivocal and was made under less-than-ideal conditions. Against this, the defense successfully established that Dela Cruz’s alibi was physically impossible to have been fabricated, as he was shown to be in a distant location at the time of the crime. Where the prosecution’s evidence is weak and the defense of alibi is strong and corroborated, the constitutional presumption of innocence must prevail. Proof beyond reasonable doubt demands a moral certainty of guilt, which was not met in this case. The Court emphasized that it is better to acquit a guilty person than to convict an innocent one.