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 illuminated by a streetlight. She also testified that she heard her husband struggling and saw the accused fleeing with a bag.

The defense interposed alibi and denial. The accused claimed he was in a different city attending a fiesta at the time of the incident, supported by the testimonies of his friend and a barangay official.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness identification and rejecting the defense of 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.

On appeal, 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 an 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.

a. Eyewitness Identification Was Fraught with Doubt
The Court found the eyewitness identification by Maria Santos unreliable. She testified that she recognized the accused because of a streetlight, but the distance and lighting conditions were not clearly established. Moreover, her initial description to the police was vague. Positive identification must be credible and free from any doubt. In this case, the identification did not meet the standard of moral certainty.

b. Inconsistencies in the Prosecution’s Evidence
The prosecution failed to present the murder weapon or any forensic evidence linking the accused to the crime. The testimony of Maria Santos also contained inconsistencies regarding the sequence of events, which were not adequately explained.

c. Defense of Alibi May Prevail When Identity Is Doubtful
While alibi is generally a weak defense, it may be considered when the identity of the perpetrator is not established beyond reasonable doubt. Here, the accused presented credible corroboration for his presence elsewhere. Given the doubt in the eyewitness identification, the defense of alibi assumes significance.

2. The award of damages is set aside due to the acquittal.

Since the accused is acquitted, no civil liability arises. All damages awarded by the lower courts are deleted.

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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.