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 also testified that she heard the accused demand money from her husband before stabbing him. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The trial court convicted the accused, giving full credence to the eyewitness testimony and rejecting the alibi.

ISSUE

Whether the trial court erred in convicting the accused based on the eyewitness identification despite the defense of alibi.

RULING

The Supreme Court AFFIRMED the conviction.

RATIONALE

1. Credibility of Eyewitness Testimony The Court held that the eyewitness identification by Maria Santos was credible, consistent, and given in a straightforward manner. She had a clear view of the accused, whom she knew prior to the incident, and her testimony remained unshaken during cross-examination. The trial court’s assessment of witness credibility is entitled to great respect and will not be disturbed on appeal unless there is a clear showing of error.

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 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. In this case, the accused failed to establish the physical impossibility, as the distance between the crime scene and the place where he claimed to be was not insurmountable within the timeframe of the crime.

3. Elements of Robbery with Homicide All elements of the crime were proven beyond reasonable doubt: (a) the taking of personal property with intent to gain; (b) the use of violence or intimidation against a person; (c) the property taken belongs to another; and (d) the homicide was committed by reason or on occasion of the robbery. The prosecution established that the killing occurred during the robbery, making the accused liable for the special complex crime.

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court of Quezon City, Branch 90, finding accused-appellant Juan Dela Cruz GUILTY beyond reasonable doubt of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.