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 Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in his hometown in Bulacan at the time of the incident, attending a fiesta. The trial court convicted Dela Cruz and sentenced him to reclusion perpetua. Hence, this appeal.

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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 prevail over the positive identification by an eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled that the prosecution failed to prove the guilt of the accused beyond reasonable doubt. While the eyewitness, Maria Reyes, positively identified Dela Cruz, her testimony was fraught with inconsistencies on material points. She initially stated she saw the accused at 8:00 PM, but later changed it to 7:30 PM. She also could not describe the clothing of the accused with certainty. Moreover, no physical evidence (e.g., fingerprints, DNA, murder weapon) linked Dela Cruz to the crime. The Court emphasized that in criminal cases, the identity of the accused must be established with moral certainty. Here, the evidence fell short of that standard.

2. On the defense of alibi vs. positive identification.

The Court held that while alibi is generally a weak defense, it may be accepted if the accused proves that it was physically impossible for him to be at the crime scene. Dela Cruz presented credible evidence, including affidavits from barangay officials and photographs, showing his presence in Bulacan, which is approximately 50 kilometers away from Quezon City. Given the traffic conditions and distance, it was physically impossible for him to have been at the crime scene at the time of the incident. The positive identification, being unreliable, cannot overcome the defense of alibi under these circumstances.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Regional Trial Court of Quezon City, Branch 90, in Criminal Case No. Q-18-12345 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. The Director of the Bureau of Corrections is ordered to IMMEDIATELY RELEASE the accused from custody unless he is being held for another lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.