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

Ponente: J. Reyes

FACTS

Accused-appellant 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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the 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. The Court of Appeals 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 and in accordance with prevailing jurisprudence.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled in the NEGATIVE. The prosecution failed to prove the guilt of the accused beyond reasonable doubt.

Weakness of the Prosecution’s Evidence: The Court found the testimony of the lone eyewitness, Maria Reyes, to be inconsistent and unreliable. Upon meticulous review of the records, her testimony on material points—such as the lighting conditions, the distance from the scene, and the description of the perpetrator’s clothing—was fraught with contradictions. The Court has consistently held that the testimony of a single witness, if credible and positive, is sufficient to convict. However, when such testimony is inconsistent and uncorroborated, it cannot overcome the constitutional presumption of innocence.
Failure to Establish Corpus Delicti: The prosecution also failed to establish the corpus delicti of the robbery. While the homicide was proven, there was insufficient evidence to show that property was actually taken by the accused with intent to gain. The testimony did not clearly detail what was stolen, and no stolen items were recovered from or linked to the accused.

2. On the defense of alibi versus positive identification.

The Court held that while alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness, this principle does not apply when the positive identification is itself doubtful and unreliable.

In this case, since the eyewitness identification was found to be flawed and insufficient, the defense of alibi, which was supported by the credible testimonies of several disinterested witnesses who corroborated the accused’s presence in another location, assumes significance. The defense was able to demonstrate that it was physically impossible for Dela Cruz to have been at the crime scene at the time of its commission.

3. On the award of damages.

In view of the acquittal, the award of damages by the lower courts is SET ASIDE. An accused who is acquitted is entitled to be freed from all civil liability arising from the crime charged, unless the acquittal is based on reasonable doubt and a civil action for damages is separately filed.

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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 that his guilt has not been proven beyond reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention, unless he is being held for another lawful cause.

Let an entry of final judgment be issued immediately.

SO ORDERED.