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, 2018, 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 Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. Hence, this appeal.

ISSUE

Whether the trial court erred in convicting accused-appellant of Robbery with Homicide despite the failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

NO. The Supreme Court AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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RATIONALE

1. Credibility of Prosecution Witness
The Court upheld the trial court’s assessment of the credibility of eyewitness Maria Reyes. The trial court’s factual findings, especially on witness credibility, are accorded great weight and respect unless there is a clear showing of error. Reyes gave a consistent and straightforward account of the incident, and her testimony remained unshaken during cross-examination.

2. Weakness of Alibi
The defense of 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 elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility, as the city where he claimed to be was only a few hours away from the crime scene.

3. Elements of Robbery with Homicide
The crime of Robbery with Homicide requires: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is done with animo lucrandi; and (d) on the occasion of the robbery, homicide is committed. All elements were proven beyond reasonable doubt:
– Dela Cruz took cash and jewelry from Santos’s house.
– The items belonged to Santos.
– The taking was done with animo lucrandi (intent to gain).
– The killing of Santos occurred during the robbery, as evidenced by the eyewitness testimony and the proximity of the stolen items to the victim’s body.

4. Conspiracy
Although Dela Cruz acted alone, conspiracy is not required for Robbery with Homicide. The crime is a single offense, and the homicide need not be intended; it is sufficient that the killing occurred by reason or on the occasion of the robbery.

5. Penalty
Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the trial court.

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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.