Defenses of Alibi and Denial 

Defenses of –– Alibi and denial are inherently weak defenses and must be brushed aside when the prosecution has sufficiently and positively ascertained the identity of the accused; it is only axiomatic that positive testimony prevails over negative testimony. (People vs. Clemeno, G.R. No. 215202, March 14, 2018)

(Etino vs. People, G.R. No. 206632, Feb. 14, 2018)

––      Denial and alibi are inherently weak defenses and must be brushed aside when the prosecution has sufficiently and positively ascertained the identity of the accused; a categorical and positive identification of an accused, without any showing of ill-motive on the part of the witness testifying on the matter, prevails over denial, which is a negative and self-serving evidence undeserving of real weight in law unless substantiated by clear and convincing evidence. (People vs. Sisracon, G.R. No. 226494, Feb. 14, 2018)

––      Denial, if unsubstantiated by clear and convincing evidence, is a self-serving assertion that deserves no weight in law, as in this case; likewise, 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; accused-appellant’s alibi cannot prevail over the positive identification of his own step-daughters who had no improper motive to testify falsely. (People vs. Molejon, G.R. No. 208091, April 23, 2018)

(People vs. Empuesto,G.R. No. 218245, Jan. 17, 2018)

––      Denial is an intrinsically weak defense that further crumbles when it comes face-to-face with the positive identification and straightforward narration of the prosecution witness; for the defense of alibi to prosper, appellant must prove through clear and convincing evidence that not only was he in another place at the time of the commission of the crime but also that it was physically impossible for him to be at the scene of the crime; application. (People vs. Cirbeto, G.R. No. 231359, Feb. 07, 2018)

––      If not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law; they are considered with suspicion and always received with caution, not only because they are inherently weak and unreliable but also because they are easily fabricated and concocted; denial cannot prevail over the positive testimony of prosecution witnesses who were not shown to have any ill-motive to testify against the appellant. (People vs. Bringcula, G.R. No. 226400, Jan. 24, 2018)

––      In light of the victim’s positive declaration, petitioner’s unsubstantiated defense must fail following the doctrine that “positive identification prevails over denial and alibi.” (Perez vs. People, G.R. No. 201414, April 18, 2018)

––      Is weak compared to the positive identification of the appellants as the perpetrators; alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law; where there is the least possibility of the presence of the accused at the crime scene, the alibi will not hold water. (People vs. Golidan, G.R. No. 205307, Jan. 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; denial is an intrinsically weak defense which must be buttressed with strong evidence of non-culpability to merit credibility; alibi, on the one hand, is viewed with suspicion because it can easily be fabricated; how to prosper. (People vs. Ganaba, G.R. No. 219240, April 04, 2018)

––      Positive testimony is generally given more weight than the defenses of denial and alibi which are held to be inherently weak defenses because they can be easily fabricated; however, the defenses of denial and alibi should not be so easily dismissed by the Court as untrue; the same can be said of untruthful accusations, in that they can be as easily concocted; Lejano v. People, cited; if found credible, the defenses of denial and alibi may be considered complete and legitimate defenses; the burden of proof does not shift by the mere invocation of said defenses; the presumption of innocence remains in favor of the accused; alibi, how to prove; physical impossibility, construed. (Aliling vs. People, G.R. No. 230991, June 11, 2018)

––      The defense of alibi and denial proffered by the accused-appellant were inherently weak and which cannot prevail over the positive identification by the victim that it was the accused-appellant who raped her. (People vs. Agalot, G.R. No. 220884, Feb. 21, 2018)

––      The time-honored principle in jurisprudence that positive identification prevails over alibi since the latter can easily be fabricated and is inherently unreliable finds its significance in this case; 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; the accused-appellant’s denial is negative and self-serving evidence undeserving of weight in law; it cannot be given a greater evidentiary value over the testimony of credible witnesses who testify on affirmative matters. (People vs. Ragasa, G.R. No. 202863, Feb. 21, 2018)

––      The twin defenses of denial and alibi are inherently weak, and easily crumble against the positive identification made by a reliable eye witness; significantly, a denial and alibi will not prevail if corroborated not by credible witnesses, but by the accused’s relatives and friends; this was the important dictum laid by the Court in People v. Adriano, et al,andPeople v. Las Piñas. (People vs. Grabador, Jr., G.R. No. 227504, June 13, 2018)

Source: Supreme Court of the Philippines