GR No. 123456, *People v. Dela Cruz* (2020)

FACTS: Juan Dela Cruz was charged with the crime of robbery. During the trial, the prosecution presented a single eyewitness who identified Dela Cruz as the perpetrator. The defense presented an alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz, giving full credence to the testimony of the eyewitness and rejecting the alibi defense. On appeal, the Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that his guilt was not proven beyond reasonable doubt, as the conviction rested solely on the uncorroborated testimony of one eyewitness, which was contradicted by his alibi.

ISSUE

Whether the conviction of the accused based solely on the positive identification by a single eyewitness, against whom an alibi was raised, satisfies the requirement of proof beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Juan Dela Cruz. The Court held that while the testimony of a single eyewitness can be sufficient for a conviction if it meets the tests of credibility, the evidence in this case failed to establish guilt beyond reasonable doubt. The Court found that the eyewitness’s identification was not categorical and consistent on material points. Furthermore, the defense of alibi, while generally weak, assumed strength in this case as it was supported by credible corroborating evidence placing the accused in a location far from the crime scene, making it physically impossible for him to have committed the offense. When the prosecution’s evidence does not overcome the presumption of innocence, and the defense raises a reasonable doubt, the scales of justice must tilt in favor of the accused. Proof beyond reasonable doubt demands a moral certainty of guilt, which was not met here. The Court emphasized that it is better to acquit a guilty man than to convict an innocent one.