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. She testified that she saw the accused for only a few seconds in a dimly lit room, yet she claimed she could recognize him clearly. The Court noted that no physical evidence (e.g., fingerprints, DNA) linked the accused to the crime scene. Moreover, there was no evidence that the witness had a prior familiarity with the accused sufficient to make a reliable identification under stressful conditions.

2. Alibi Was Corroborated and Physically Possible to Maintain
While alibi is generally a weak defense, it may prevail when the prosecution’s evidence is weak. Here, the accused presented credible witnesses who were not shown to have any motive to falsely testify. The defense established that the accused was in Bulacan, which is far from Quezon City, making it physically impossible for him to have been at the crime scene at the time of the incident. The prosecution failed to present any evidence to rebut the alibi’s physical impossibility.

3. Proof Beyond Reasonable Doubt Was Not Met
The constitutional presumption of innocence requires that the prosecution prove the guilt of the accused beyond reasonable doubt. Any doubt must be resolved in favor of the accused. In this case, the evidence presented by the prosecution was insufficient to overcome this presumption. The Court reiterated that it is better to acquit a guilty person than to convict an innocent one.

4. Circumstantial Evidence Was Insufficient
The prosecution relied solely on the eyewitness account without any corroborating circumstantial evidence. For circumstantial evidence to sustain a conviction, there must be more than one circumstance, the facts from which the inferences are derived must be proven, and the combination of all circumstances must produce a conviction beyond reasonable doubt. These requirements were not met.

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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 some other lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.