G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, supported by the testimonies of his relatives.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness identification 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 the eyewitness.
3. Whether the award of damages is proper.

RULING

1. The prosecution failed to prove guilt beyond reasonable doubt.

The Supreme Court reversed the conviction and acquitted the accused.

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 Maria Santos. While the Court generally respects the trial court’s assessment of witness credibility, it found several material inconsistencies and improbabilities in her testimony that eroded its reliability.

Doubtful Identification: Maria Santos claimed she recognized the accused because the room was “well-lit,” yet she also stated the power was out that evening and they were using a candle. This inconsistency cast serious doubt on her ability to positively identify the perpetrator.
Lapse in Reporting: She did not immediately name the accused to the responding police officers, only doing so two days later. The Court found this delay unnatural for a witness who claimed to have clearly recognized a former neighbor.
* No Corroborative Evidence: No other evidence (e.g., fingerprints, recovered stolen items, weapon) linked the accused to the crime. The prosecution’s case was built entirely on a single, questionable identification.

2. The defense of alibi, under the circumstances, casts reasonable doubt.

While alibi is generally a weak defense, it may be considered when the prosecution’s evidence is weak. The Court held that the prosecution’s evidence was not strong enough to overcome the defense of alibi. The testimonies of the accused’s relatives, though self-serving, were consistent and remained unrebutted by any concrete evidence placing the accused at the crime scene. The distance between Bulacan and Quezon City made it highly improbable for the accused to have committed the crime and returned in the timeframe suggested.

3. The award of damages is set aside due to acquittal.

Upon acquittal, the civil liability ex delicto is extinguished. The Court emphasized that a judgment of acquittal operates to extinguish all liabilities arising from the criminal act.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz is REVERSED and SET ASIDE. Accused-appellant Juan Dela Cruz is ACQUITTED of the crime of Robbery with Homicide on the ground of reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention unless he is being held for another lawful cause. The awards of civil indemnity, moral damages, and exemplary damages are DELETED.

SO ORDERED.