G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

Juan Dela Cruz was charged with the crime of Robbery with Homicide under Article 294 of the Revised Penal Code. The prosecution alleged that on January 15, 2018, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, supported by the testimonies of his relatives.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness identification and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Hence, this appeal before the Supreme Court.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence over the positive identification by the eyewitness.
3. Whether the award of damages is proper.

RULING

1. The prosecution failed to prove guilt beyond reasonable doubt.

The Supreme Court reversed the conviction and acquitted the accused.

The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and the accused is presumed innocent until proven guilty beyond reasonable doubt. The prosecution’s case rested solely on the testimony of one eyewitness, Maria Santos. While the testimony of a single witness can be sufficient for conviction if credible and positive, the Court found several inconsistencies and improbabilities in her testimony:

– She claimed the room was well-lit, yet in her sworn statement given to police immediately after the incident, she stated it was “dim.”
– She testified she saw the accused’s face clearly, but on cross-examination, she admitted she only saw his profile and he was wearing a cap pulled low over his forehead.
– No physical evidence (e.g., fingerprints, DNA, recovered stolen items) linked the accused to the crime.
– The alleged motive—that the accused was a former neighbor with a grudge—was not substantiated.

The Court held that positive identification must be clear, consistent, and credible. In this case, the eyewitness identification was fraught with doubt and could not overcome the constitutional presumption of innocence.

2. The defense of alibi, under the circumstances, casts reasonable doubt.

While alibi is generally considered a weak defense, it may be credited when the prosecution’s evidence is weak. Here, the accused presented credible corroborative testimonies from disinterested witnesses (barangay officials and a priest) who confirmed his presence at a fiesta in Bulacan, which was more than 100 kilometers away from Quezon City, making it physically impossible for him to have been at the crime scene at the time of the incident.

The Court reiterated the doctrine that for alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the locus criminis. This requirement was satisfied.

Given the doubtful identification by the sole eyewitness and the physically impossible alibi, the evidence for the prosecution failed to meet the standard of proof beyond reasonable doubt.

3. The award of damages is set aside due to acquittal.

Upon acquittal, all civil liabilities ex delicto are extinguished. The accused is not liable to pay indemnity, moral, or exemplary damages arising from the criminal act. Any civil liability must be pursued in a separate civil action.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz is REVERSED and SET ASIDE. Accused-appellant Juan Dela Cruz is ACQUITTED of the crime of Robbery with Homicide on the ground of reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention unless he is being held for another lawful cause. The awards of civil indemnity, moral damages, and exemplary damages are DELETED.

SO ORDERED.