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 also testified that she heard her husband shouting the name “Juan” during the struggle.

The defense interposed the defense of alibi, claiming that at the time of the incident, the accused was in his house in a different barangay, approximately 15 kilometers away, attending a birthday party of a relative. Several relatives and friends corroborated his alibi.

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

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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 in light of the positive identification by the eyewitness.

RULING

1. The prosecution failed to prove the guilt of the accused beyond reasonable doubt.

The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and the accused is presumed innocent until proven guilty. The evidence must establish guilt to a moral certainty, leaving no room for reasonable doubt.

In this case, the eyewitness identification was unreliable. The witness, Maria Santos, claimed to have recognized the accused because the room was “well-lit,” but no evidence was presented regarding the type and wattage of the lighting. Moreover, she admitted during cross-examination that she only saw the perpetrator’s back as he fled. Her claim that she heard her husband shout “Juan” is hearsay and cannot be considered as affirmative evidence of the accused’s identity. The name “Juan” is also very common, and no other evidence linked the accused to the crime scene, such as fingerprints, DNA, or recovered stolen items.

2. The defense of alibi, when supported by credible witnesses and not physically impossible, can prevail over weak identification.

The Court reiterated the doctrine that alibi is inherently weak, but it gains strength when the prosecution’s evidence is equally weak. 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 crime scene.

Here, the accused presented multiple disinterested witnesses who consistently testified to his presence at a party 15 kilometers away. Traveling 15 kilometers at the time of the incident (around 10:00 PM) would have taken considerable time, making it physically impossible for him to have been at the crime scene. Given the prosecution’s failure to present strong, positive, and categorical evidence of identification, the defense of alibi must be sustained.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of Juan dela Cruz for Robbery with Homicide is REVERSED and SET ASIDE. Accused-appellant Juan dela Cruz is ACQUITTED on the ground of reasonable doubt. The Director of the Bureau of Corrections is ordered to cause his immediate release, unless he is being lawfully held for another cause.

SO ORDERED.