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 her husband shouting the accused’s name during the struggle. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family reunion 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 before the Supreme Court.

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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. On the proof of guilt beyond reasonable doubt YES.

The Supreme Court held that the prosecution successfully established the guilt of the accused beyond reasonable doubt. The positive identification by Maria Santos, who had no ill motive to falsely testify, was clear and consistent. She had a good view of the accused, whom she knew prior to the incident, and her testimony remained unwavering even during cross-examination. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial.

2. On the defense of alibi NO.

The defense of alibi cannot prosper in light of the positive identification by the eyewitness. For alibi to be credible, 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. The accused failed to establish physical impossibility, as the location of the family reunion was only a few hours away from the crime scene by vehicle. Thus, the defense of alibi was correctly rejected by the lower courts.

3. On the qualifying circumstance of homicide YES.

The Court ruled that the killing was a direct consequence of the robbery, as the evidence showed that the homicide was committed on the occasion or by reason of the robbery. The fact that the victim was killed while resisting the unlawful taking of his property satisfies the elements of Robbery with Homicide under Article 294 of the Revised Penal Code. The intent to rob was evident from the taking of cash and jewelry, and the homicide was perpetrated to facilitate the robbery or to eliminate resistance.

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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 in toto.

Costs against accused-appellant.

SO ORDERED.