GR No. 123456, January 1, 2023
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Robbery with Homicide. The prosecution presented evidence that Dela Cruz entered a convenience store, declared a hold-up, and shot the security guard who resisted, resulting in the guard’s death. The Regional Trial Court convicted Dela Cruz. On appeal, the Court of Appeals affirmed the conviction. Dela Cruz now appeals to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, claiming the eyewitness identification was unreliable due to poor lighting and that his extrajudicial confession was obtained without the assistance of counsel.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused for Robbery with Homicide despite alleged deficiencies in the eyewitness identification and the admissibility of his extrajudicial confession.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction.

The Court held that the totality of the evidence presented by the prosecution established the guilt of the accused beyond reasonable doubt. Regarding the eyewitness identification, the Court found that the store was sufficiently illuminated by fluorescent lights, and the witness had a clear, unobstructed view of the accused from a short distance for a considerable duration, making the identification credible and reliable. As to the extrajudicial confession, the Court ruled that even assuming it was inadmissible for having been obtained without counsel, the conviction can still stand based on the strength of the other evidence, particularly the positive identification by the credible eyewitness and the corroborating physical evidence. The crime of Robbery with Homicide was sufficiently proven by the confluence of the unlawful taking of property with violence or intimidation and the killing of the victim, which occurred by reason or on the occasion of the robbery.