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, in Quezon City, 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, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua.

On appeal, Dela Cruz argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in the eyewitness’s testimony and the weakness of the evidence linking him to the crime.

ISSUE

Whether the trial court erred in convicting accused-appellant Juan Dela Cruz of Robbery with Homicide despite alleged inconsistencies in the prosecution’s evidence and the defense of alibi.

RULING

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

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DOCTRINE

1. Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible eyewitness.
2. Inconsistencies in minor details do not impair the credibility of a witness, especially when the core testimony remains consistent and credible.
3. Robbery with Homicide is a composite crime where the homicide is committed by reason or on occasion of the robbery. The prosecution must prove the robbery and the killing, and that the latter was committed by reason or on the occasion of the former.

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RATIO DECIDENDI

1. Credibility of the Eyewitness
The Court found the testimony of Maria Reyes credible and consistent on material points. She positively identified Dela Cruz as the person she saw fleeing the crime scene with a bloodied knife. Minor inconsistencies in her testimony regarding the time or weather conditions did not affect her credibility, as they pertained to trivial matters and did not alter the substance of her account.

2. Weakness of Alibi
Dela Cruz’s alibi was unsubstantiated. 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 have been at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe.

3. Elements of Robbery with Homicide
The prosecution proved all elements of Robbery with Homicide:
– Robbery was established through testimony and evidence of missing cash and jewelry.
– Homicide was proven by the autopsy report showing fatal stab wounds.
– The killing was committed on the occasion of the robbery, as the evidence showed the victim was stabbed when he resisted the robbery.

4. Moral Certainty of Guilt
The totality of evidence—eyewitness testimony, physical evidence, and the weak alibi—led to moral certainty of Dela Cruz’s guilt beyond reasonable doubt.

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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.