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 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 the victim, 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 trial court gave credence to the prosecution’s evidence, convicted the accused of Murder, and sentenced him to reclusion perpetua.

The accused appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in appreciating the qualifying circumstance of treachery.

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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.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The positive identification of the accused by an eyewitness who had no motive to falsely testify prevails over the defense of alibi, which is inherently weak. Alibi requires proof of physical impossibility for the accused to have been at the scene of the crime, which the defense failed to establish. The testimony of Maria Reyes was clear, consistent, and credible.

2. On the qualifying circumstance of treachery.

The Supreme Court AGREED that treachery was present. The attack was sudden and from behind, without any warning, giving the victim no opportunity to defend himself. This method of execution ensured the accomplishment of the killing without risk to the accused. Hence, the crime was properly qualified as Murder.

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DISPENSITIVE

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Murder and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.