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, 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 Court ACQUITS accused-appellant Juan Dela Cruz on the ground of reasonable doubt.

The Court held that while the eyewitness was consistent in his identification, the physical evidence and the circumstances of the identification cast serious doubt on its reliability. The witness claimed to have seen the incident from 50 meters away on a poorly lit night, yet gave a detailed description of the assailant’s face. This testimony was contradicted by the medico-legal report, which indicated the victim’s wounds were inconsistent with the witness’s account of the relative positions of the assailant and the victim. Furthermore, the defense of alibi, though generally weak, was corroborated by credible documentary evidence placing the accused in another location. For alibi to prosper, it is not enough to prove that the accused was elsewhere when the crime was committed; he must also demonstrate that it was physically impossible for him to have been at the scene of the crime. In this case, the distance and travel time made it physically impossible for Dela Cruz to have committed the crime. The prosecution’s evidence, taken in its entirety, failed to overcome the constitutional presumption of innocence. Where the evidence admits two possibilities, one consistent with innocence and another with guilt, the Court must acquit. The guilt of the accused must be proved beyond reasonable doubt, and any doubt must be resolved in favor of the accused.