G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

Juan dela Cruz was charged with the crime of Robbery with Homicide under Article 294 of the Revised Penal Code. The prosecution alleged that on January 15, 2018, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, which was about 50 kilometers away.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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DOCTRINE

1. Eyewitness Identification The testimony of a single eyewitness, if positive and credible, is sufficient to support a conviction. The assessment of the credibility of witnesses is best undertaken by the trial court, and its findings are generally not disturbed on appeal unless there is a clear showing of error or arbitrariness.
2. Defense of Alibi Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime.
3. Robbery with Homicide When homicide is committed by reason or on the occasion of a robbery, the crime is Robbery with Homicide, and the intent to rob must precede the killing. All elements must be proven beyond reasonable doubt.

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RATIO DECIDENDI

1. Credibility of the Eyewitness.
The Court found the testimony of Maria Santos to be clear, consistent, and credible. She had a good opportunity to see the accused because the room was illuminated, and she recognized him as a former neighbor. The trial court’s assessment of her demeanor and credibility is entitled to great respect. The alleged inconsistencies in her testimony were minor and did not affect the core of her account.

2. Weakness of the Defense of Alibi.
The accused failed to prove that it was physically impossible for him to be at the crime scene. The distance between Bulacan and Quezon City (approximately 50 km) could be traversed by vehicle in about one to two hours. Hence, the alibi could not overcome the positive identification by the eyewitness.

3. Elements of Robbery with Homicide Proven.
All elements of Robbery with Homicide were established:
– There was unlawful taking of personal property (cash and jewelry).
– The taking was with intent to gain and accomplished with violence or intimidation.
– Homicide was committed on the occasion of the robbery.
– The accused was positively identified as the perpetrator.

4. Penalty.
The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the RTC correctly imposed reclusion perpetua.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.