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) convicted Dela Cruz, 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 (CA) 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. The prosecution failed to prove guilt beyond reasonable doubt.

The Supreme Court reversed the conviction.

The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and the accused is presumed innocent until proven guilty beyond reasonable doubt. The prosecution’s case rested solely on the testimony of a single eyewitness, Maria Reyes.

Upon meticulous review, the Court found Reyes’ testimony fraught with inconsistencies and irreconcilable doubts regarding material points:
Her account of the lighting conditions at the time she allegedly saw the accused was contradictory.
Her description of the accused’s clothing and direction of flight was inconsistent with physical evidence.
She had a prior unresolved dispute with the accused’s family, casting doubt on her motive and credibility.

In this case, the defense presented:
Credible and consistent testimonies from multiple disinterested witnesses (relatives and a barangay official) placing Dela Cruz at a gathering 50 kilometers away.
Documentary evidence (group photos with timestamp and a signed barangay logbook) supporting his presence elsewhere.
The prosecution failed to rebut this evidence or prove that it was physically possible for Dela Cruz to commute the distance in the short timeframe involved.

Given the weak and unreliable prosecution evidence, the corroborated defense of alibi must be sustained. The positive identification, being flawed, cannot trump the established physical impossibility.

3. The award of damages is rendered moot and academic due to the acquittal.

Since the accused-appellant is acquitted on reasonable doubt, the civil liability ex delicto is extinguished. No damages arising from the crime can be awarded. Any claim for civil liability must be pursued in a separate civil action.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is REVERSED and SET ASIDE.

Accused-appellant Juan Dela Cruz is ACQUITTED on the ground of reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention unless he is being held for another lawful cause.

The Director of the Bureau of Corrections is directed to implement this decision and inform the Court of the action taken within five (5) days from receipt.

SO ORDERED.