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 Court of Appeals erred in affirming the conviction of the accused-appellant for Murder despite the alleged weakness of the prosecution’s evidence and the strength of his defense of alibi.

RULING

No. The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for the crime of Murder.

The Court held that the positive identification of the accused by a credible eyewitness who had no ill motive to testify falsely prevails over the defense of alibi. Alibi is inherently weak and must be established by clear and convincing evidence, proving not only that the accused was elsewhere when the crime was committed but that it was physically impossible for him to have been at the scene of the crime. In this case, the accused failed to demonstrate such physical impossibility, as the distance between the crime scene and his alleged location was traversable within a short period. Furthermore, the trial court’s assessment of the eyewitness’s credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor and manner of testifying. The elements of Murder, including the qualifying circumstance of treachery, were sufficiently proven by the prosecution. The sudden and unprovoked attack from behind, which deprived the victim of any chance to defend himself, clearly constituted treachery. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.