"The defense of denial and alibi, as held by the Court of Appeals, is weak compared to the positive identification of the appellants as the perpetrators.[49] Alibi and denial, if not substantiated by clear and convincing evidence, are negative and self-serving evidence undeserving of weight in law.[50] Where there is the least possibility of the presence of the accused at the crime scene, the alibi will not hold water.[51] In this matter, the Court has consistently ruled as follows:
The Court has considered the defense of denial and alibi put up by the accused, but finds them relatively weak and insufficient to overcome the positive and categorical identification of the accused as perpetrators. The rule is that the defense of denial, when unsubstantiated by clear and convincing evidence, is negative and self-serving and merits no weight in law and cannot be given greater evidentiary value than the testimony of credible witnesses who testified on affirmative matters.[52] (Citations omitted.)
Both the trial court and the Court of Appeals found the defense of denial and alibi to be insufficient to overthrow the prosecution's evidence against the appellants, who failed to prove that it was physically impossible for them to be at the scene of the crime when the incidents occurred."
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE,
VS.
EDUARDO GOLIDAN Y COTO-ONG, FRANCIS NACIONALES Y FERNANDEZ, AND TEDDY OGSILA Y TAHIL, ACCUSED, EDUARDO GOLIDAN Y COTO-ONG AND FRANCIS NACIONALES Y FERNANDEZ, ACCUSED-APPELLANTS.
G.R. No. 205307, January 11, 2018.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/63799
