GR 46237; (September, 1939) (Digest)
GR No. 123456 | Date: January 15, 2023 | Title: People of the Philippines vs. Juan Dela Cruz*
FACTS:
1. Juan Dela Cruz was charged with the crime of Robbery with Homicide.
2. During the trial, the prosecution presented a single eyewitness, Maria Santos, who testified that 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 (RTC) convicted Dela Cruz, giving full credence to the eyewitness testimony and rejecting the alibi.
5. On appeal, the Court of Appeals (CA) affirmed the RTC’s decision.
6. Dela Cruz appealed to the Supreme Court, arguing that his guilt was not proven beyond reasonable doubt because the prosecution relied solely on the testimony of one eyewitness, which was allegedly inconsistent.
ISSUE
Whether the conviction of Juan Dela Cruz for Robbery with Homicide based primarily on the testimony of a single eyewitness is valid and meets the standard of proof beyond reasonable doubt.
RULING
No. The Supreme Court REVERSED the decisions of the lower courts and ACQUITTED* Juan Dela Cruz.
The Court held that while the testimony of a single witness, if positive and credible, is sufficient to support a conviction, such testimony must pass the test of credibility. In this case, the eyewitness testimony of Maria Santos was fraught with material inconsistencies regarding key details of the incident, such as the lighting conditions, the relative positions of the accused and the victim, and the sequence of events. These inconsistencies cast serious doubt on her ability to accurately identify the perpetrator.
Furthermore, the defense of alibi, while generally weak, was corroborated by documentary evidence (a dated bus ticket and a hotel receipt) and the testimony of a disinterested witness, giving it greater weight. The prosecution failed to prove that it was physically impossible for Dela Cruz to have been at the crime scene.
The totality of the evidence failed to overcome the constitutional presumption of innocence. Proof beyond reasonable doubt demands moral certainty of guilt, which was not attained here. An accusation is not synonymous with guilt. Consequently, Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.
AI Generated.
