GR No. 123456, January 1, 2023
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 eyewitness testimony from Maria Reyes, who claimed she saw Dela Cruz stab Santos during a heated argument. The defense, however, presented an alibi, asserting that Dela Cruz was in a different city at the time of the incident, supported by the testimony of a barangay official. The Regional Trial Court convicted Dela Cruz of Murder, giving full credence to the eyewitness account and rejecting the alibi defense. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the lower courts erred in disregarding his alibi and in finding the testimony of the lone eyewitness credible beyond reasonable doubt.

ISSUE

Whether the conviction of accused-appellant Juan Dela Cruz for the crime of Murder is supported by proof beyond reasonable doubt.

RULING

NO. The conviction is REVERSED. Accused-appellant Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt.

The Court held that the prosecution failed to discharge its burden of proving the guilt of the accused beyond reasonable doubt. The lone eyewitness testimony was fraught with inconsistencies on material points, such as the lighting conditions and the relative positions of the individuals involved, which cast serious doubt on its reliability. In contrast, the defense of alibi was supported by credible documentary evidence and the testimony of a disinterested barangay official, which collectively established the physical impossibility for the accused to have been at the crime scene. While alibi is generally a weak defense, it gains strength where, as in this case, the prosecution’s evidence is itself weak and insufficient to prove the identity of the perpetrator. Where the evidence for the prosecution and the defense are evenly balanced, the constitutional presumption of innocence must tilt the scales in favor of the accused. Consequently, the guilt of the accused-appellant has not been proven to a moral certainty, warranting an acquittal.