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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he refused to comply. 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 Regional Trial Court (RTC) found the accused 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 the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Court held that the positive identification by the eyewitness, Maria Santos, who had no ill motive to falsely testify against the accused, prevailed over the defense of alibi. Her testimony was clear, consistent, and credible. She had a sufficient opportunity to see the accused during the incident, as the robbery occurred in her well-lit living room, and she was face-to-face with the accused for several minutes.

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

The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the scene of the crime. In this case, the accused merely claimed to be in a different city, which is not an insurmountable distance. Moreover, alibi becomes even less credible when, as here, there is positive identification by a credible witness.

3. The qualifying circumstance of homicide was properly appreciated.

For Robbery with Homicide to be convicted, it is sufficient that the homicide be committed by reason or on the occasion of the robbery. The prosecution established that the killing of Pedro Santos was directly linked to the robbery, as it occurred when the victim resisted the unlawful taking. The accused’s act of stabbing the victim was integral to the commission of the robbery, thus qualifying the crime to Robbery with Homicide.

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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 the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Costs against accused-appellant.

SO ORDERED.