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, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry.

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 at the time of the incident.

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

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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 be given credence over the positive identification by an eyewitness.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the prosecution successfully established all elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons;
– Homicide was committed as a consequence or on the occasion of the robbery.

The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. Her positive identification of Dela Cruz as the perpetrator was categorical and unwavering. The Court emphasized that positive identification prevails over alibi, especially when the alibi is not physically impossible and is not corroborated by credible witnesses.

2. The defense of alibi cannot prevail over positive identification.

The defense of alibi requires proof that the accused was at another place at the time of the commission of the offense and that it was physically impossible for him to be at the crime scene. Dela Cruz failed to prove physical impossibility. The distance between the crime scene and his alleged location was not insurmountable within the timeframe of the crime. Moreover, alibi is inherently weak and easily fabricated.

The Court also noted that the defense failed to show any ill motive on the part of the eyewitness to falsely testify against Dela Cruz.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.