1.

The defenses of alibi and denial cannot prevail over the positive identification
and unwavering positive assertions. (Ronnie Sumbillo, et al. vs. PP., G.R. No.
167464, Jan. 21, 2010)

2. People of the Philippines v. Lilio U. Achas[13] is instructive:

By the distinctive nature of rape cases, conviction usually rests solely on

the basis of the testimony of the victim, provided that such testimony is
credible, natural, convincing, and consistent with human nature and the
normal course of things. Accordingly, the Court has consistently
adhered to the following guiding principles in the review of similar
cases, to wit: (1) an accusation for rape can be made with facility; while
the accusation is difficult to prove, it is even more difficult for the
accused, though innocent, to disprove; (2) considering that, in the nature
of things, only two persons are usually involved in the crime of rape, the
testimony of the complainant must be scrutinized with extreme caution;
and (3) the evidence for the prosecution must stand or fall on its own
merits, and cannot be allowed to draw strength from the weakness of the
evidence for the defense.

Likewise, no ill motive was adduced as to why VVV would impute to Ayade,
her own father, so grave a charge. The alleged ill motive of Ayades mother-in-law,
GGG, is highly illogical. It is certainly absurd that GGG, VVVs own grandmother,
would fabricate a very disturbing story just because she and Ayade had a shallow
dispute on the non-payment of some electric bill. Ayade's imputation against GGG
is but a lame and pathetic excuse in order to exculpate himself from the bestial
and devious act he did to his own daughter. Thus, absent any showing of ill
motive on the part of the eyewitnesses, specifically of VVV, a categorical,
consistent, and positive identification of appellant prevails over denial and alibi.
Unless substantiated by clear and convincing proof, denial and alibi are negative,
self-serving and undeserving of any weight in law.[16]
3. In People v. Palomar, we explained why alibi is a weak and unreliable
defense:

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. It cannot prevail over the positive identification of the accused by
eyewitnesses who had no improper motive to testify falsely.

x x x.

We have also declared that in case of alibi, the accused must show that he
had strictly complied with the requirements of time and place: In the case of
alibi, it is elementary case law that the requirements of time and place be
strictly complied with by the defense, meaning that the accused must not
only show that he was somewhere else but that it was also physically
impossible for him to have been at the scene of the crime at the time it was
committed.

4. PEOPLE OF THE PHILIPPINES, APPELLEE, VS. DONATO BULASAG Y

ARELLANO ALIAS“DONG”, APPELLANT.
[G.R. No. 172869, July 28, 2008]
Nothing is more settled in criminal law jurisprudence than that denial and alibi cannot
prevail over the positive and categorical testimony of the witness. Denial is an
intrinsically weak defense which must be buttressed with strong evidence of non-
culpability to merit credibility. Alibi is an inherently weak defense, which is viewed with
suspicion and received with caution because it can easily be fabricated. For alibi to
prosper, appellant must prove not only that he was at some other place when the crime
was committed but that it was physically impossible for him to be at the locus criminis at
the time of its commission.
5. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GONZALO PENASO @
“LULU”,accused–appellant.
[G.R. No. 121980. February 23, 2000]
We find complainant’s testimony credible, while appellant’s defenses of alibi and denial
are lacking in truth and candor. Nothing is more settled in criminal law jurisprudence
than that alibi and denial cannot prevail over the positive and categorical testimony of
the complainant.Alibi is an inherently weak defense, which is viewed with suspicion and
received with caution because it can easily be fabricated. Denial is an intrinsically weak
defense which must be buttressed with strong evidence of non-culpability to merit
credibility. We find that despite his stance that several persons watched him
demonstrate how to cook banana chips in Ubay, Bohol in the morning of November 16,
1989, appellant failed to present any disinterested witness to support his claim. For alibi
to prosper, it is not enough that accused show he was elsewhere at the time the crime
was committed, but there must also be clear and convincing proof that it was impossible
for him to be at the locus criminis at the time of its commission.
With respect to the appellant’s claim that the victim was attending her classes at the
time she was raped, we note that complainant’s explanation that it was their vacant
period, was not rebutted by the defense. All told, we see no reason to depart from the
rule that positive identification of the malefactor prevails over the defenses of alibi and
denial.

6. PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BOBBY AGUNOS, accused-

appellants.
[G.R. No. 130961. October 13, 1999]
The shopworn rule is that for alibi to prosper, it is not enough that accused was at some
place else at the time of the commission of the crime, it must also be proved by clear
and convincing evidence that it was physically impossible for him to have been at the
scene of the crime at the time of its commission and commit the crime. His aunt’s
testimony that he was seen sleeping outside the polling place from 1:00 oclock to 3:00
oclock in the early morning of May 9, 1995 must be taken with a grain of salt inasmuch
as accused-appellant failed to present other disinterested witnesses aside from a close
relation to corroborate his claim that he was nowhere near complainants home at the
time of the commission of the crime.

7. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOVITO BARONA, FELIPE

FERRARIZ, ELPIDIO SARA, JR., @ “Matias Sara” and ROBERTO BARONA, @ “Pewe
Barona,” accused-appellants.
[G.R. No. 119595. January 25, 2000]
The bare denials and alibi interposed by accused-appellants when juxtaposed with the
positive declarations of the prosecution witnesses is not worthy of credence.
Recognized as inherently weak defenses, which is the usual refuge of scoundrels, alibi
and denial must be buttressed by other convincing evidence of non-culpability to merit
credibility. It all the more fails where the assailants were positively identified by credible
witness, against whom no ulterior motive can be attributed, as in this case.