GR No. 123456 | Date: January 15, 2023 | Title: People of the Philippines v. Juan Dela Cruz*

FACTS:
1. Juan Dela Cruz was charged with the crime of Robbery with Homicide.
2. During trial, the prosecution presented a single eyewitness, Maria Santos, who testified she saw Dela Cruz stab the victim during a robbery.
3. The defense presented an alibi, claiming Dela Cruz was in a different city at the time of the crime.
4. The Regional Trial Court convicted Dela Cruz, giving full credence to the eyewitness testimony and rejecting the alibi.
5. On appeal, Dela Cruz argued that his conviction was based solely on the uncorroborated testimony of one witness, which was insufficient for proof beyond reasonable doubt.

Whether the conviction of the accused for Robbery with Homicide based solely on the positive identification by a single eyewitness, without corroborating evidence, meets the required standard of proof beyond reasonable doubt.

*
No. The Supreme Court REVERSED the conviction.
1. While the testimony of a single witness can be sufficient for conviction if credible and positive, the evidence must still survive the test of reason and produce moral certainty.
2. In this case, the eyewitness testimony was fraught with inconsistencies on material points (e.g., lighting conditions, distance, identifying features) and was not corroborated by any physical or circumstantial evidence.
3. The defense of alibi, though inherently weak, was supported by credible documentary evidence (a dated official receipt from the other city).
4. The prosecution failed to discharge its burden of proving guilt beyond reasonable doubt. The equipoise rule applies; where the evidence of both sides is evenly balanced, the presumption of innocence must prevail.
5. Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.

AI Generated.