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

Ponente: PER CURIAM

FACTS

Juan dela Cruz was charged with the crime of Murder under Article 248 of the Revised Penal Code. The prosecution alleged that on January 15, 2018, in Quezon City, the accused, with treachery and evident premeditation, shot and killed Pedro Santos.

During trial, the prosecution presented an eyewitness, Maria Reyes, who testified that she saw the accused, whom she knew personally, approach the victim from behind and shoot him without any warning or provocation. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city at the time of the incident.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt of Murder, appreciating the qualifying circumstance of treachery. The court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs.

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 qualifying circumstance of treachery was properly appreciated.
3. Whether the defense of alibi should be given credence.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Supreme Court upheld the findings of the lower courts. The positive identification of the accused by eyewitness Maria Reyes, who had no motive to falsely testify, prevails over the defense of alibi. Alibi is inherently weak and cannot stand against positive identification, especially when the accused failed to prove that it was physically impossible for him to be at the crime scene.

2. The qualifying circumstance of treachery was properly appreciated.

The Court agreed that the attack was treacherous. The victim was shot from behind without any opportunity to defend himself or retaliate. The manner of execution ensured the assailant’s safety from any defensive act, thereby qualifying the killing as Murder.

3. The defense of alibi was correctly rejected.

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 be at the scene. The accused failed to establish such physical impossibility. The place where he claimed to be was not so far as to preclude his presence at the crime scene.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan dela Cruz for the crime of Murder is AFFIRMED with MODIFICATION.

Accused-appellant is sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole. He is ordered to pay the heirs of Pedro Santos the following amounts:
Civil Indemnity ₱75,000.00;
Moral Damages ₱75,000.00;
Exemplary Damages ₱75,000.00; and
Temperate Damages ₱50,000.00.

All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.