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 positive identification 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.

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 appeal is granted. The conviction is reversed and set aside. Accused-appellant Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.

The Court held that while positive identification generally prevails over alibi, the identification in this case was fraught with serious doubt. The eyewitness testified that the incident occurred at night in a poorly lit area, and he only had a fleeting glance at the assailant from a considerable distance. This casts uncertainty on the reliability of his identification. Furthermore, the defense presented credible documentary and testimonial evidence, including time-stamped receipts and the testimony of a disinterested barangay official, strongly corroborating the alibi. In criminal cases, the burden of proof lies with the prosecution, and guilt must be established beyond a shadow of doubt. Where the evidence admits of two possibilities, one consistent with innocence and the other with guilt, the accused must be acquitted. Here, the prosecution evidence failed to meet the required moral certainty for a conviction.