For alibi to prosper, requirements of time and place must be strictly met

As regards appellant's alibi, the Court has time and again ruled that alibi is the weakest of defenses because it is easy to fabricate but difficult to prove. It cannot prevail over the positive identification of the accused by witnesses. For the defense to prosper, the requirements of time and place (or distance) must be stricly met: it is not enough to prove that the accused was somewhere else when the crime was committed; he must also demonstrate by clear and convincing evidence that it was physically impossible for him to have been at the scene of the crime during its commission. In the case before us, such physical impossibility had not been proven, and in fact, quite the opposite was shown. According to the Fiscal Fidel Sarmiento, the distance between Pawa and Bogtong, which are adjacent barangays, could be negotiated in ten to twenty minutes by crossing the river; and appellant admitted that in travelling between Bogtong and Pawa to peddle his wares, he would usually cross the river instead of passing through San Joaquin. [G.R. No. 88043. December 9, 1996]