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 under stressful conditions. The Court noted that no physical evidence (e.g., fingerprints, DNA, recovered stolen items) linked the accused to the crime. Moreover, the witness had no prior interaction with the accused that would make her identification infallible. The Court cited People v. Teehankee Jr., which requires a high degree of certainty in eyewitness identification, especially where life and liberty are at stake.

2. Alibi Was Corroborated and Physically Impossible to Disprove
While alibi is generally a weak defense, it may be accepted if the accused proves he was so far away that it was physically impossible for him to have been at the crime scene. Here, the accused presented credible witnesses and documentary evidence (photographs, testimonies of barangay officials) showing his presence in Bulacan, approximately 50 kilometers away, during the time of the incident. The prosecution failed to rebut this evidence with concrete proof of the accused’s presence at the crime scene.

3. Presumption of Innocence and Proof Beyond Reasonable Doubt
The Court reiterated the constitutional presumption of innocence. Any doubt must be resolved in favor of the accused. The prosecution bears the burden of proving guilt beyond reasonable doubt. In this case, the evidence presented fell short of that standard. The Court cited People v. Ganguso, which held that when the evidence is capable of two interpretations, one consistent with innocence and the other with guilt, the interpretation favoring innocence must be adopted.

4. Moral Certainty Required in Criminal Cases
Conviction must be based on moral certainty, not just probability. The inconsistencies in the prosecution’s narrative and the lack of corroborative evidence created reasonable doubt as to the accused’s guilt. The Court emphasized that it is better to acquit a guilty person than to convict an innocent one.

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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.