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 Pedro Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz, whom she had known for five years, stab the victim during a street altercation. The defense interposed 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, finding the positive identification by the eyewitness credible and the alibi weak. The Court of Appeals affirmed the conviction. Dela Cruz now appeals, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, emphasizing the inherent weakness of alibi as a defense and questioning the credibility of the single eyewitness.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for Murder based on the testimony of a single eyewitness, despite the defense of alibi.

RULING

No. The Court of Appeals did not err. The appeal is denied, and the conviction is affirmed.

The Supreme 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 and denial. The Court reiterated the well-established doctrine that alibi is inherently weak and must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the scene of the crime. In this case, the accused failed to demonstrate such impossibility. Conversely, the testimony of eyewitness Maria Reyes was found to be clear, categorical, consistent, and given in a straightforward manner, surviving rigorous cross-examination. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the direct opportunity to observe the witness’s demeanor. Where there is no evidence that the witness was actuated by improper motive, her positive testimony is accorded full faith and credit. The prosecution thus discharged its burden of proving the guilt of the accused beyond reasonable doubt. The qualifying circumstance of treachery was also properly established, as the attack was sudden and unexpected, depriving the victim of any chance to defend himself.