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, with intent to rob. During the commission of the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. The defense, on the other hand, 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 before the Supreme Court.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

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

The Supreme Court held that the prosecution successfully established all the 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 on the occasion or by reason of the robbery.

The eyewitness testimony of Maria Santos was found to be credible, consistent, and categorical. She had a clear view of the accused during the incident, and her identification was not tainted by any ill motive. The Court emphasized that positive identification, when credible, prevails over alibi and denial.

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

The defense of alibi requires the accused to prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility. The place where he claimed to be was not so far as to preclude his presence at the crime scene. Moreover, alibi is inherently weak and easily fabricated, and it must yield to the positive identification by a credible witness.

3. The qualifying circumstance of homicide was properly appreciated.

The Court ruled that the homicide was committed by reason or on the occasion of the robbery. The evidence showed that the killing was directly linked to the robbery, as the victim resisted the unlawful taking. Thus, the crime was properly classified as Robbery with Homicide, a special complex crime under Article 294 of the Revised Penal Code.

—

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.