GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz, without any provocation, stab Santos from behind. The defense, however, presented an alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not sufficiently established.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of Murder.

RULING

No, the Court of Appeals did not err. The Supreme Court DENIED the appeal and AFFIRMED the conviction of Juan Dela Cruz for Murder.

The Court held that the positive and categorical identification of the accused by eyewitness Maria Reyes, who had no motive to testify falsely, prevails over the weak defense of alibi. Alibi is inherently unreliable and must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the crime scene, which the defense failed to demonstrate. Furthermore, the Court found that the manner of attacka sudden stabbing from behind without warningensured the execution of the crime without risk to the assailant arising from any defense the victim might make, thereby satisfying the elements of treachery (alevosia) which qualified the killing as Murder under Article 248 of the Revised Penal Code. The findings of fact of the trial court, affirmed by the Court of Appeals, are entitled to great weight and respect, and there is no compelling reason to disturb them.