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 Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the alleged weakness of the prosecution’s evidence and the strength of the defense of alibi.

RULING

The Supreme Court ACQUITS the accused-appellant. The conviction is REVERSED and SET ASIDE.

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RATIONALE

1. Eyewitness Identification Was Not Sufficiently Reliable
The Court emphasized that for eyewitness identification to sustain a conviction, it must be credible, consistent, and categorical. In this case, the identification by Maria Santos was fraught with doubt. The prosecution failed to establish that the lighting conditions at the time of the incident were adequate for a clear and positive identification. The witness’s claim that the room was “well-lit” was not corroborated by any physical evidence or testimony regarding the source, brightness, or positioning of the light. Moreover, the witness admitted during cross-examination that she only saw the perpetrator for a few seconds and was in a state of panic. The Court has consistently held that identification under conditions of poor visibility and stress is inherently unreliable.

2. Alibi as a Defense
While alibi is generally considered a weak defense, it may be accepted if the accused proves that it was physically impossible for him to be at the crime scene. Here, the accused presented credible evidence, including testimonies of disinterested witnesses and documentary proof (photographs and text messages), showing that he was in Bulacan, approximately 50 kilometers away, during the time of the crime. Given the traffic conditions and distance, it was physically impossible for him to have been at the crime scene in Quezon City at the time of the incident.

3. Presumption of Innocence and Proof Beyond Reasonable Doubt
The constitutional presumption of innocence prevails unless the prosecution overcomes it with proof beyond reasonable doubt. In this case, the prosecution’s evidence was insufficient to meet this high standard. The lone eyewitness account was unreliable, and no other corroborative evidence (e.g., fingerprints, DNA, recovered stolen items) was presented. Any doubt must be resolved in favor of the accused.

4. Circumstantial Evidence
The prosecution did not present any circumstantial evidence that would form an unbroken chain leading to the accused’s guilt. The elements of robbery with homicide were not proven beyond reasonable doubt, particularly the identity of the perpetrator.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the conviction of 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. The Director of the Bureau of Corrections is ordered to IMMEDIATELY RELEASE the accused-appellant from custody unless he is being held for another lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.