Defense of Alibi

Defense of –– Alibi is an inherently weak defense and should be rejected when the identity of the accused is sufficiently and positively  established by the prosecution; for alibi to overcome the prosecution’s evidence, the defense must successfully prove the element of physical impossibility  of the presence of the accused at the   crime scene at the time the offense was committed; physical impossibility in relation to alibi takes into consideration not only the geographical distance between the scene of the crime and the place where the accused maintains he was, but more importantly, the accessibility between these points. (People vs. Banayat, G.R. No. 215749, March 14, 2018)

––      Alibi is an inherently weak defense because it is easy to fabricate and highly unreliable; to merit approbation, the appellant must adduce clear and convincing evidence that he was in a place other than the situs criminis at the time when the crime was committed, such that it was physically impossible for him to have been at the scene of the crime when it was committed; furthermore, alibi cannot prevail over the positive and credible testimony of the prosecution witness that accused-appellant committed the crime. (People vs. Badillos, G.R. No. 215732, June 06, 2018)

––      Alibi is one of the weakest defenses not only because it is inherently frail and unreliable, but also because it is easy to fabricate and difficult to check or rebut; how to prosper. (People vs. Agalot, G.R. No. 220884, Feb. 21, 2018)

––      Appellants’ defense of alibi is unavailing; in order that alibi might prosper, it is not enough to prove that the accused has been somewhere else during the commission of the crime; it must also be shown that it would have been impossible for him to be anywhere within the vicinity of the crime scene; appellants miserably failed to discharge this burden. (People vs.Vibal, Jr., G.R. No. 229678, June 20, 2018)          

––      For a defense of alibi to prosper, the accused-appellant must prove not only that he was somewhere else when the crime was committed but he must also satisfactorily establish that it was physically impossible for him to be at the crime scene at the time of its commission. (People vs. Clemeno, G.R. No. 215202, March 14, 2018)

––      For alibi to prosper, the accused must prove that he was somewhere else when the crime was committed and that it was physically impossible for him to have been at the scene of the crime; physical impossibility refers to the distance between the place where the appellant was when the crime transpired and the place where it was committed, as well as the facility of access between the two places. (People vs. Bongos, G.R. No. 227698, Jan. 31, 2018)

––      In order that alibi might prosper, it is not enough to prove that the accused has been somewhere else during the commission of the crime; it must also be shown that it would have been impossible for him to be anywhere within the vicinity of the crime scene; given the positive identification by the victim of the accused as the culprit, and the lack of physical impossibility for said appellant to be at the scene of the crime at the time of its commission, his defenses of denial and alibi crumble like a sand fortress; his defense of extortion must likewise fail considering that the same was not substantiated by competent and independent evidence. (People vs. Villalobos, G.R. No. 228960, June 11, 2018)

––      It is settled that positive identification prevails over alibi because it can easily be fabricated and is inherently unreliable; People v. Dadao, cited; in the case at bar, other than his testimony, the accused failed to present disinterested witnesses to corroborate his claim; he could only muster a measly self-serving alibi to defend himself; such defense fails to convince the Court of the accused’s innocence especially since the victim had positively and convincingly identified him as her abuser. (People vs. Bugna, G.R. No. 218255, April 11, 2018)

––      Nothing is more settled in criminal law jurisprudence than that alibi and denial cannot prevail over the positive and categorical testimony and identification of the complainant; for the defense of alibi to prosper, the accused must prove that he was somewhere else when the offense was committed and that he was so far away that it was not possible for him to have been physically present at the place of the crime or at its immediate vicinity at the time of its commission; denial is an inherently weak defense and constitutes self-serving negative evidence, which cannot be accorded greater evidentiary weight than the positive declaration by a credible witness. (People vs. Rupal, G.R. No. 222497, June 27, 2018)

––      Positive identification prevails over alibi since the latter can easily be fabricated and is inherently unreliable. (People vs. Dela Peña, G.R. No. 219581, Jan. 31, 2018) ––      The defense of alibi is an inherently weak defense which cannot prevail over the positive and credible testimony of the prosecution witness that accused-appellant has committed the crime; for such defense to prosper, he must prove that he was somewhere else when the offense was committed and that he was so far away that it was not possible for him to have been physically present at the place of the crime or at its immediate vicinity at the time of its commission. (People vs. Corpuz, G.R. No. 215320, Feb. 28, 2018)

Source: Supreme Court of the Philippines