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

Ponente: J. Reyes

FACTS

Accused-appellant 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, 2015, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Lopez, a neighbor who claimed to have seen Dela Cruz fleeing the scene. The defense, however, presented an alibi, asserting that Dela Cruz was in a different city attending a family reunion at the time of the crime. The trial court convicted Dela Cruz, giving credence to the eyewitness testimony and rejecting the alibi. The court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in disregarding his alibi.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should have been given credence.

RULING

1. On the proof of guilt beyond reasonable doubt.
The Supreme Court AFFIRMED the conviction. The Court held that the positive identification by eyewitness Maria Lopez, who had no motive to falsely testify, was credible and sufficient to establish Dela Cruz’s presence at the crime scene. Her testimony was consistent and remained unshaken during cross-examination. The Court emphasized that positive identification prevails over alibi and denial, especially when the alibi is not physically impossible or strongly corroborated.

2. On the defense of alibi.
The Court REJECTED the defense of alibi. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to demonstrate this impossibility. The distance between the crime scene and the location of the family reunion was not so great as to preclude his presence at the crime scene. Moreover, alibi is inherently weak and easily fabricated.

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DOCTRINE

– Positive identification by a credible witness prevails over alibi and denial.
– For alibi to be credible, the accused must prove that it was physically impossible for him to be at the crime scene at the time of its commission.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.